Finding Number Compliance Deficiencies 2024-005 Special Education Cluster: Procurement, Suspension, and Debarment Federal Agency: United States Department of Education Federal program Name: Special Education Cluster Assistance Listing Number: 84.024, 84.173 Federal Award Identification Number and Year: Unknown Pass-through Agency: Wisconsin Department of Public Instruction Pass-Through Numbers: 2024-585264-DPI-FLOW-341, 2024-585264-DPI-PRESCH-347 Award Period: 07/01/2023 – 06/30/2024 Compliance Requirements Affected: Procurement, Suspension, and Debarment Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: 2 CFR 200.320 Methods of Procurement state that if the small purchases method is used, price or rate quotations must be obtained from an adequate number of qualified sources (at least 2) and that the procurement is vendor aggregate, not single item. Proposals must be solicited from an adequate number of qualified offerors. For purchases greater than $250,000, either a sealed bid or proposal is required. 2 CFR 200.214 requires non-Federal entities to follow suspension and debarment regulations outlined in 2 CFR part 180. When a non-Federal entity enters into a covered transactions with an entity at a lower tier, the non-Federal entity must verify that the entity, as described in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: During our testing of procurement transactions of the program, we noted that the District was not consistently following the procurement policy, specifically related to small purchases threshold. These purchases were not supported by an adequate number of quotes (at least two) or proposals to ensure the District is prudent with the monies used towards the program. Additionally, we noted the District does not have procedures in place for verifying that vendors are not debarred, suspended or otherwise excluded. Questioned costs: None Context: During our testing of procurement transactions of the program, we noted that the District was not consistently following the procurement policy, specifically related to small purchases threshold. In our sample of twelve vendors subject to procurement requirements, we noted the District did not obtain and/or retain documentation for an adequate number of price quotes for one vendor. In our testing of suspension and debarment, we noted that the District did not retain documentation related to suspension and debarment for all three vendors that were selected for testing. Cause: The District did not follow their Federal Funds Procurement and Suspension and Debarment Policy related to appropriate methods of procurement and suspension and debarment. Section III – Findings and Questioned Costs – Major Federal and State Programs (Continued) Finding Number Compliance Deficiencies 2024-005 Special Education Cluster: Procurement, Suspension, and Debarment (Continued) Effect: Obtaining price quotes and proposals from an adequate number of vendors allows the District to use federal funds in the most fiscally responsible way. The lack of price quotes or proposals may cause the District to overpay for supplies or services. Additionally, the District could contract with a vendor that has been suspended or debarred from receiving Federal funds. Repeat Finding: No Recommendation: We recommend that the District review its procedures to ensure that the District’s procurement policy and suspension and debarment policy are being consistently followed. We further recommend that the District require all grant administrators to receive training on Federal procurement and suspension and debarment regulations. View of Responsible Officials: There is no disagreement with this audit finding. See corrective action plan.
Program: Special Supplemental Nutrition Program for Women, Infants, and Children (WIC) Assistance Listing No.: 10.557 Federal Grantor: U.S. Department of Agriculture Passed-through: California Department of Public Health Award No.: 22-10307 Award Year: 2024 Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Material Weakness in Internal Control over Compliance and Material Non-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 County 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. Per 2 CFR Section 180.300, when a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General 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 200.318(i) Procurement records. The recipient or subrecipient must maintain records sufficient to detail the history of each procurement transaction. These records must include the rationale for the procurement method, contract type selection, contractor selection or rejection, and the basis for the contract price. 2 CFR 200.327 Contract provisions. The recipient's or subrecipient's contracts must contain the applicable provisions described in Appendix II to Part 200—Contract Provisions for Non-Federal Entity Contracts Under Federal Awards. Condition: During our testing of the County’s provisions for procurement requirements, we noted the following: 1. For two (2) out of two (2) contracts selected for testing there was no evidence that the County verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract. 2. For two (2) out of two (2) contracts selected for testing, the County did not include all applicable provisions described in 2 CFR 200 Appendix II. 3. For one (1) out of two (2) contracts selected for testing with a contract value of $600,000, the County could not provide documentation of the history of the procurement, including the rationale for the method of procurement, selection of contract type, basis for contractor selection, and the basis for the contract price. Cause: The County did not follow their policy to verify the information described in the condition prior to entering the transactions. The County did not follow their policy documenting the history of the procurement, including the rationale for the method of procurement, selection of contract type, basis for contractor selection, and the basis for the contract price. The County’s policy does not include the requirement to include all applicable provisions identified in 2 CFR 200 Appendix II in its contracts. Effect: Failure to implement and maintain a proper control process could result in payments to vendors that are suspended or debarred or improper awarding of contracts under the procurement guidance. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of two (2) out of twelve (12) procurement contracts were tested. This represented a total of $2,285,000 in contracted services under the grant. Repeat Finding from Prior Years: No. Recommendation: We recommend the County strengthen its policies and procedures to ensure that the verification of the debarment and suspension is documented and retained, the history of procurement transactions is documented and retained in its official records, and that contracts include all applicable provisions of 2 CFR 200 Appendix II. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Special Supplemental Nutrition Program for Women, Infants, and Children (WIC) Assistance Listing No.: 10.557 Federal Grantor: U.S. Department of Agriculture Passed-through: California Department of Public Health Award No.: 22-10307 Award Year: 2024 Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Material Weakness in Internal Control over Compliance and Material Non-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 County 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. Per 2 CFR Section 180.300, when a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General 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 200.318(i) Procurement records. The recipient or subrecipient must maintain records sufficient to detail the history of each procurement transaction. These records must include the rationale for the procurement method, contract type selection, contractor selection or rejection, and the basis for the contract price. 2 CFR 200.327 Contract provisions. The recipient's or subrecipient's contracts must contain the applicable provisions described in Appendix II to Part 200—Contract Provisions for Non-Federal Entity Contracts Under Federal Awards. Condition: During our testing of the County’s provisions for procurement requirements, we noted the following: 1. For two (2) out of two (2) contracts selected for testing there was no evidence that the County verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract. 2. For two (2) out of two (2) contracts selected for testing, the County did not include all applicable provisions described in 2 CFR 200 Appendix II. 3. For one (1) out of two (2) contracts selected for testing with a contract value of $600,000, the County could not provide documentation of the history of the procurement, including the rationale for the method of procurement, selection of contract type, basis for contractor selection, and the basis for the contract price. Cause: The County did not follow their policy to verify the information described in the condition prior to entering the transactions. The County did not follow their policy documenting the history of the procurement, including the rationale for the method of procurement, selection of contract type, basis for contractor selection, and the basis for the contract price. The County’s policy does not include the requirement to include all applicable provisions identified in 2 CFR 200 Appendix II in its contracts. Effect: Failure to implement and maintain a proper control process could result in payments to vendors that are suspended or debarred or improper awarding of contracts under the procurement guidance. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of two (2) out of twelve (12) procurement contracts were tested. This represented a total of $2,285,000 in contracted services under the grant. Repeat Finding from Prior Years: No. Recommendation: We recommend the County strengthen its policies and procedures to ensure that the verification of the debarment and suspension is documented and retained, the history of procurement transactions is documented and retained in its official records, and that contracts include all applicable provisions of 2 CFR 200 Appendix II. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Special Supplemental Nutrition Program for Women, Infants, and Children (WIC) Assistance Listing No.: 10.557 Federal Grantor: U.S. Department of Agriculture Passed-through: California Department of Public Health Award No.: 22-10307 Award Year: 2024 Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Material Weakness in Internal Control over Compliance and Material Non-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 County 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. Per 2 CFR Section 180.300, when a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General 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 200.318(i) Procurement records. The recipient or subrecipient must maintain records sufficient to detail the history of each procurement transaction. These records must include the rationale for the procurement method, contract type selection, contractor selection or rejection, and the basis for the contract price. 2 CFR 200.327 Contract provisions. The recipient's or subrecipient's contracts must contain the applicable provisions described in Appendix II to Part 200—Contract Provisions for Non-Federal Entity Contracts Under Federal Awards. Condition: During our testing of the County’s provisions for procurement requirements, we noted the following: 1. For two (2) out of two (2) contracts selected for testing there was no evidence that the County verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract. 2. For two (2) out of two (2) contracts selected for testing, the County did not include all applicable provisions described in 2 CFR 200 Appendix II. 3. For one (1) out of two (2) contracts selected for testing with a contract value of $600,000, the County could not provide documentation of the history of the procurement, including the rationale for the method of procurement, selection of contract type, basis for contractor selection, and the basis for the contract price. Cause: The County did not follow their policy to verify the information described in the condition prior to entering the transactions. The County did not follow their policy documenting the history of the procurement, including the rationale for the method of procurement, selection of contract type, basis for contractor selection, and the basis for the contract price. The County’s policy does not include the requirement to include all applicable provisions identified in 2 CFR 200 Appendix II in its contracts. Effect: Failure to implement and maintain a proper control process could result in payments to vendors that are suspended or debarred or improper awarding of contracts under the procurement guidance. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of two (2) out of twelve (12) procurement contracts were tested. This represented a total of $2,285,000 in contracted services under the grant. Repeat Finding from Prior Years: No. Recommendation: We recommend the County strengthen its policies and procedures to ensure that the verification of the debarment and suspension is documented and retained, the history of procurement transactions is documented and retained in its official records, and that contracts include all applicable provisions of 2 CFR 200 Appendix II. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Health Center Program Cluster Assistance Listing No.: 93.224; 93.527 Federal Grantor: U.S. Department of Health and Human Services Passed-through: N/A Award No.: 4 H8GCS48295‐01‐01 Award Year: 12/01/2022 ‐ 12/31/2023 Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Material Weakness in Internal Control over Compliance and Material Non-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 County 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. Per 2 CFR Section 180.300, when a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General 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 200.318(i) Procurement records. The recipient or subrecipient must maintain records sufficient to detail the history of each procurement transaction. These records must include the rationale for the procurement method, contract type selection, contractor selection or rejection, and the basis for the contract price. 2 CFR 200.327 Contract provisions. The recipient's or subrecipient's contracts must contain the applicable provisions described in Appendix II to Part 200—Contract Provisions for Non-Federal Entity Contracts Under Federal Awards. Condition: During our testing of the County’s provisions for procurement requirements, we noted the following: 1. For one (1) out of three (3) contracts selected for testing, there was no evidence that the County verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract. 2. For one (1) out of three (3) contracts selected for testing, the County did not include all applicable provisions described in 2 CFR 200 Appendix II. 3. For one (1) out of three (3) contracts selected for testing with a total contract value of $2,616,000, the County could not provide documentation of the history of the procurement, including the rationale for the method of procurement, selection of contract type, basis for contractor selection, and the basis for the contract price. Cause: The County did not follow their policy to verify the information described in the condition prior to entering the transactions. The County did not follow their policy documenting the history of the procurement, including the rationale for the method of procurement, selection of contract type, basis for contractor selection, and the basis for the contract price. The County’s policy does not include the requirement to include all applicable provisions identified in 2 CFR 200 Appendix II in its contracts. Effect: Failure to implement and maintain a proper control process could result in payments to vendors that are suspended or debarred or improper awarding of contracts under the procurement guidance. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of three (3) out of three (3) procurement contracts were tested. This represented a total of $21,679,640 in contracted services under the grant. Repeat Finding from Prior Years: No. Recommendation: We recommend the County strengthen its policies and procedures to ensure that the verification of the debarment and suspension is documented and retained, the history of procurement transactions is documented and retained in its official records, and that contracts include all applicable provisions of 2 CFR 200 Appendix II. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Health Center Program Cluster Assistance Listing No.: 93.224; 93.527 Federal Grantor: U.S. Department of Health and Human Services Passed-through: N/A Award No.: 4 H8GCS48295‐01‐01 Award Year: 12/01/2022 ‐ 12/31/2023 Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Material Weakness in Internal Control over Compliance and Material Non-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 County 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. Per 2 CFR Section 180.300, when a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General 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 200.318(i) Procurement records. The recipient or subrecipient must maintain records sufficient to detail the history of each procurement transaction. These records must include the rationale for the procurement method, contract type selection, contractor selection or rejection, and the basis for the contract price. 2 CFR 200.327 Contract provisions. The recipient's or subrecipient's contracts must contain the applicable provisions described in Appendix II to Part 200—Contract Provisions for Non-Federal Entity Contracts Under Federal Awards. Condition: During our testing of the County’s provisions for procurement requirements, we noted the following: 1. For one (1) out of three (3) contracts selected for testing, there was no evidence that the County verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract. 2. For one (1) out of three (3) contracts selected for testing, the County did not include all applicable provisions described in 2 CFR 200 Appendix II. 3. For one (1) out of three (3) contracts selected for testing with a total contract value of $2,616,000, the County could not provide documentation of the history of the procurement, including the rationale for the method of procurement, selection of contract type, basis for contractor selection, and the basis for the contract price. Cause: The County did not follow their policy to verify the information described in the condition prior to entering the transactions. The County did not follow their policy documenting the history of the procurement, including the rationale for the method of procurement, selection of contract type, basis for contractor selection, and the basis for the contract price. The County’s policy does not include the requirement to include all applicable provisions identified in 2 CFR 200 Appendix II in its contracts. Effect: Failure to implement and maintain a proper control process could result in payments to vendors that are suspended or debarred or improper awarding of contracts under the procurement guidance. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of three (3) out of three (3) procurement contracts were tested. This represented a total of $21,679,640 in contracted services under the grant. Repeat Finding from Prior Years: No. Recommendation: We recommend the County strengthen its policies and procedures to ensure that the verification of the debarment and suspension is documented and retained, the history of procurement transactions is documented and retained in its official records, and that contracts include all applicable provisions of 2 CFR 200 Appendix II. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Health Center Program Cluster Assistance Listing No.: 93.224; 93.527 Federal Grantor: U.S. Department of Health and Human Services Passed-through: N/A Award No.: 4 H8GCS48295‐01‐01 Award Year: 12/01/2022 ‐ 12/31/2023 Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Material Weakness in Internal Control over Compliance and Material Non-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 County 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. Per 2 CFR Section 180.300, when a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General 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 200.318(i) Procurement records. The recipient or subrecipient must maintain records sufficient to detail the history of each procurement transaction. These records must include the rationale for the procurement method, contract type selection, contractor selection or rejection, and the basis for the contract price. 2 CFR 200.327 Contract provisions. The recipient's or subrecipient's contracts must contain the applicable provisions described in Appendix II to Part 200—Contract Provisions for Non-Federal Entity Contracts Under Federal Awards. Condition: During our testing of the County’s provisions for procurement requirements, we noted the following: 1. For one (1) out of three (3) contracts selected for testing, there was no evidence that the County verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract. 2. For one (1) out of three (3) contracts selected for testing, the County did not include all applicable provisions described in 2 CFR 200 Appendix II. 3. For one (1) out of three (3) contracts selected for testing with a total contract value of $2,616,000, the County could not provide documentation of the history of the procurement, including the rationale for the method of procurement, selection of contract type, basis for contractor selection, and the basis for the contract price. Cause: The County did not follow their policy to verify the information described in the condition prior to entering the transactions. The County did not follow their policy documenting the history of the procurement, including the rationale for the method of procurement, selection of contract type, basis for contractor selection, and the basis for the contract price. The County’s policy does not include the requirement to include all applicable provisions identified in 2 CFR 200 Appendix II in its contracts. Effect: Failure to implement and maintain a proper control process could result in payments to vendors that are suspended or debarred or improper awarding of contracts under the procurement guidance. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of three (3) out of three (3) procurement contracts were tested. This represented a total of $21,679,640 in contracted services under the grant. Repeat Finding from Prior Years: No. Recommendation: We recommend the County strengthen its policies and procedures to ensure that the verification of the debarment and suspension is documented and retained, the history of procurement transactions is documented and retained in its official records, and that contracts include all applicable provisions of 2 CFR 200 Appendix II. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Health Center Program Cluster Assistance Listing No.: 93.224; 93.527 Federal Grantor: U.S. Department of Health and Human Services Passed-through: N/A Award No.: 4 H8GCS48295‐01‐01 Award Year: 12/01/2022 ‐ 12/31/2023 Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Material Weakness in Internal Control over Compliance and Material Non-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 County 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. Per 2 CFR Section 180.300, when a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General 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 200.318(i) Procurement records. The recipient or subrecipient must maintain records sufficient to detail the history of each procurement transaction. These records must include the rationale for the procurement method, contract type selection, contractor selection or rejection, and the basis for the contract price. 2 CFR 200.327 Contract provisions. The recipient's or subrecipient's contracts must contain the applicable provisions described in Appendix II to Part 200—Contract Provisions for Non-Federal Entity Contracts Under Federal Awards. Condition: During our testing of the County’s provisions for procurement requirements, we noted the following: 1. For one (1) out of three (3) contracts selected for testing, there was no evidence that the County verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract. 2. For one (1) out of three (3) contracts selected for testing, the County did not include all applicable provisions described in 2 CFR 200 Appendix II. 3. For one (1) out of three (3) contracts selected for testing with a total contract value of $2,616,000, the County could not provide documentation of the history of the procurement, including the rationale for the method of procurement, selection of contract type, basis for contractor selection, and the basis for the contract price. Cause: The County did not follow their policy to verify the information described in the condition prior to entering the transactions. The County did not follow their policy documenting the history of the procurement, including the rationale for the method of procurement, selection of contract type, basis for contractor selection, and the basis for the contract price. The County’s policy does not include the requirement to include all applicable provisions identified in 2 CFR 200 Appendix II in its contracts. Effect: Failure to implement and maintain a proper control process could result in payments to vendors that are suspended or debarred or improper awarding of contracts under the procurement guidance. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of three (3) out of three (3) procurement contracts were tested. This represented a total of $21,679,640 in contracted services under the grant. Repeat Finding from Prior Years: No. Recommendation: We recommend the County strengthen its policies and procedures to ensure that the verification of the debarment and suspension is documented and retained, the history of procurement transactions is documented and retained in its official records, and that contracts include all applicable provisions of 2 CFR 200 Appendix II. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Federal agency: U.S. Treasury Federal program title: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Pass-Through Agency: City of Champaign, Illinois; Champaign County, Illinois; City of Urbana, Illinois Pass-Through Number(s): 20220245; 02220246; 2224-FF-CO Award Period: 7/1/2023-12/31/2026; 3/1/2023-12/30/2023; 12/15/2023-12/31/2024; 3/1/2022-12/31/2023; 3/1/2022-12/31/2024 Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria or Specific Requirement: § 200.214 Suspension and debarment indicates nonfederal entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: The Organization did not perform the search of suspension and debarment, so it did not meet the requirements of the Uniform Guidance. As a result, the Organization could not provide supporting documentation showing that engaged vendors had gone through an appropriate suspension and debarment process. Questioned costs: N/A Context: 4 of 4 vendors selected for testing suspension and debarment, did not have documentation showing that suspension and debarment had been checked prior to entering into a contract. Cause: Error by management in understanding Uniform Guidance requirements. Effect: Lack of appropriate suspension and debarment policies could result in the Organization engaging vendors who are debarred from doing business with the United States Government and/or using federal funds in manner that is not the most efficient or economical. Repeat Finding: Repeat Finding of 2023-004. Recommendation: We recommend the Organization revised its internal controls related to suspension and debarment such that they align with the requirements of the Uniform Guidance. Views of responsible officials: The Organization has added a Procurement, Suspension and Debarment policy and will continue to verify contractors as required. The Organization will improve on documentation procedures for these verifications.
Federal agency: U.S. Treasury Federal program title: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Pass-Through Agency: City of Champaign, Illinois; Champaign County, Illinois; City of Urbana, Illinois Pass-Through Number(s): 20220245; 02220246; 2224-FF-CO Award Period: 7/1/2023-12/31/2026; 3/1/2023-12/30/2023; 12/15/2023-12/31/2024; 3/1/2022-12/31/2023; 3/1/2022-12/31/2024 Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria or Specific Requirement: § 200.214 Suspension and debarment indicates nonfederal entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: The Organization did not perform the search of suspension and debarment, so it did not meet the requirements of the Uniform Guidance. As a result, the Organization could not provide supporting documentation showing that engaged vendors had gone through an appropriate suspension and debarment process. Questioned costs: N/A Context: 4 of 4 vendors selected for testing suspension and debarment, did not have documentation showing that suspension and debarment had been checked prior to entering into a contract. Cause: Error by management in understanding Uniform Guidance requirements. Effect: Lack of appropriate suspension and debarment policies could result in the Organization engaging vendors who are debarred from doing business with the United States Government and/or using federal funds in manner that is not the most efficient or economical. Repeat Finding: Repeat Finding of 2023-004. Recommendation: We recommend the Organization revised its internal controls related to suspension and debarment such that they align with the requirements of the Uniform Guidance. Views of responsible officials: The Organization has added a Procurement, Suspension and Debarment policy and will continue to verify contractors as required. The Organization will improve on documentation procedures for these verifications.
Federal agency: U.S. Treasury Federal program title: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Pass-Through Agency: City of Champaign, Illinois; Champaign County, Illinois; City of Urbana, Illinois Pass-Through Number(s): 20220245; 02220246; 2224-FF-CO Award Period: 7/1/2023-12/31/2026; 3/1/2023-12/30/2023; 12/15/2023-12/31/2024; 3/1/2022-12/31/2023; 3/1/2022-12/31/2024 Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria or Specific Requirement: § 200.214 Suspension and debarment indicates nonfederal entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: The Organization did not perform the search of suspension and debarment, so it did not meet the requirements of the Uniform Guidance. As a result, the Organization could not provide supporting documentation showing that engaged vendors had gone through an appropriate suspension and debarment process. Questioned costs: N/A Context: 4 of 4 vendors selected for testing suspension and debarment, did not have documentation showing that suspension and debarment had been checked prior to entering into a contract. Cause: Error by management in understanding Uniform Guidance requirements. Effect: Lack of appropriate suspension and debarment policies could result in the Organization engaging vendors who are debarred from doing business with the United States Government and/or using federal funds in manner that is not the most efficient or economical. Repeat Finding: Repeat Finding of 2023-004. Recommendation: We recommend the Organization revised its internal controls related to suspension and debarment such that they align with the requirements of the Uniform Guidance. Views of responsible officials: The Organization has added a Procurement, Suspension and Debarment policy and will continue to verify contractors as required. The Organization will improve on documentation procedures for these verifications.
Federal agency: U.S. Treasury Federal program title: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Pass-Through Agency: City of Champaign, Illinois; Champaign County, Illinois; City of Urbana, Illinois Pass-Through Number(s): 20220245; 02220246; 2224-FF-CO Award Period: 7/1/2023-12/31/2026; 3/1/2023-12/30/2023; 12/15/2023-12/31/2024; 3/1/2022-12/31/2023; 3/1/2022-12/31/2024 Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria or Specific Requirement: § 200.214 Suspension and debarment indicates nonfederal entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: The Organization did not perform the search of suspension and debarment, so it did not meet the requirements of the Uniform Guidance. As a result, the Organization could not provide supporting documentation showing that engaged vendors had gone through an appropriate suspension and debarment process. Questioned costs: N/A Context: 4 of 4 vendors selected for testing suspension and debarment, did not have documentation showing that suspension and debarment had been checked prior to entering into a contract. Cause: Error by management in understanding Uniform Guidance requirements. Effect: Lack of appropriate suspension and debarment policies could result in the Organization engaging vendors who are debarred from doing business with the United States Government and/or using federal funds in manner that is not the most efficient or economical. Repeat Finding: Repeat Finding of 2023-004. Recommendation: We recommend the Organization revised its internal controls related to suspension and debarment such that they align with the requirements of the Uniform Guidance. Views of responsible officials: The Organization has added a Procurement, Suspension and Debarment policy and will continue to verify contractors as required. The Organization will improve on documentation procedures for these verifications.
Federal Agency: U.S. Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Numbers: 10.553 and 10.555 Federal Award Identification Number and Year: 2023; Federal Award Identification Number not available. Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education Pass-Through Number: 03-292 Award Period: July 1, 2023 through June 30, 2024 Compliance Requirement: Procurement, Suspension and Debarment Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matter Criteria or specific requirement: Title 2 of the U.S. Code of Federal Regulations (CFR), Section 200.214 requires non-federal entities to follow suspension and debarment regulations outlined in 2 CFR part 180. When a nonfederal entity enters into a covered transaction with an entity at a lower tier, the nonfederal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Internal controls should be designed and implemented to prevent or detect noncompliance with this requirement. Condition: Swansea Public Schools (SPS) did not obtain evidence supporting their verification that entities were not suspended, debarred, or otherwise excluded from participating in the grant award transactions. Questioned costs: None. Context: The SPS did not obtain evidence of verification of the suspension and debarment status for one (1) of two (2) entities in our sample to which the SPS incurred expenditures in excess of $25,000. Cause: Internal controls were not implemented to ensure documented evidence was obtained regarding the suspension and debarment status for all entities receiving federal funds in excess of $25,000 from SPS. Effect: Risk of noncompliance with the federal award program was elevated. It was later verified the entities in question were not suspended or debarred. Repeat Finding: No. Recommendation: We recommend SPS ensure documentation be obtained supporting the suspension and debarment status of entities to which the SPS expends greater than $25,000. Such documentation could include (1) a history of searching SAM.gov exclusions, (2) certification from the entity, or (3) a clause or condition included in the contract or subaward with the entity. Views of Responsible Officials: There is no disagreement with the audit finding.
Finding Reference Number: 2024-008. Federal Program: AL 21.027 – COVID-19 - Coronavirus State and Local Recovery Funds. Passed through Entity: County of St. Joseph, Indiana. Compliance Requirements: Procurement, Suspension, and Debarment. Type of Finding : Significant Deficiency in Internal Controls over Compliance. Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires nonfederal entities to have a procurement policy in accordance with the Uniform Guidance requirements. 2 CFR Section 200.214 requires non-federal entities to follow suspension and debarment regulations outlined in 2 CFR part 180. When a nonfederal entity enters a covered transaction with an entity at a lower tier, the nonfederal entity must verify 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. Condition and Context: There is no procedure in place to determine whether vendors are suspended or debarred. For our sample of one, representing the entire population, the entity did not have documentation to support a check of a suspension and debarment on the vendor it entered into a transaction. Questioned Costs: No costs are required to be questioned as a result of this finding as none of the vendors or subrecipients involved were actually suspended or debarred. Cause: The Organization did not have a procedure in place to require documentation be maintained that the search for suspension and debarment associated with procurement transactions in excess of the $25,000 threshold had been performed prior to procurement. Effect or Potential Effect: Costs charged to federal awards could be paid to a person/vendor that has been debarred or suspended by the Federal government. This could lead to costs charged to the federal award to be subject to disallowance resulting in noncompliance. Recommendation: We recommend the Organization implement a policy over suspension and debarment review to ensure they are maintaining compliance and controls over verifying or contracting with vendors that are allowable. Views of responsible officials: Management acknowledges the finding and understands the need to perform a review of vendors paid using federal grant funds to determine if they are suspended or debarred.
Prior Year Finding: 2023-005 Federal Agency: U.S. Department of Treasury Federal Program: COVID 19 Coronavirus State and Local Fiscal Relief Fund Assistance Listing: 21.027 Pass-Through Entity: Maryland Department of Housing and Community Development Pass-Through Award Number and Period: (7/1/2023 - 6/30/2024) Compliance Requirement: Suspension and Debarment Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Control: Per 2 CFR section 200.303(a), a non-federal entity must: Establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should comply with the 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). Compliance: Per 2 CFR section 200.214 Suspension and Debarment restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Per 2 CFR section 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM Exclusion; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Condition/Context: The suspension and debarment status of five out of five vendors with expenditures exceeding $25,000 was not verified as required by federal regulation. Questioned Costs: There are no questioned costs related to this finding as the vendors were not federally suspended or debarred. Cause: The Towns internal controls were not sufficient to ensure federal suspension and debarment regulations were followed for purchases made for the program. Effect: Failure to adhere to suspension and debarment requirements may result in the Town entering into a contract or purchase with a vendor that is suspended or debarred and not authorized to provide goods and services to the program. Recommendation: We recommend that the Town enhance its procedures and internal controls to ensure that it verifies vendors are not suspended or debarred from business prior to all goods and services charged to the program. The Town should retain documentation of procurement suspension/debarment status verifications for its vendors audit purposes. Views of Responsible Officials: Management agrees with the finding.
2024-004 U.S. Department of the Treasury COVID-19 – Coronavirus State and Local Fiscal Recovery Funds - ALN 21.027 Material Weakness in Internal Controls Over Compliance Criteria: Per 2 CFR section 200.214, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Condition: Suspension and debarment compliance was not verified for three covered transactions. Cause: Lack of appropriate oversight resulted in required suspension and debarment checks not being performed. Effect: Grant transactions are not supported adequately, and the Town is at risk of awarding contracts to vendors not eligible to participate in federal awards programs. It was determined that none of the three vendors were suspended or debarred from federal awards. Questioned Costs: None Repeat Finding from Prior Year: No. Recommendation: The Town should implement procedures to document that all contractors under covered transactions that are performing services for the grant are not suspended or debarred. Views of Responsible Official: Management agrees with the finding.
2024-004 U.S. Department of the Treasury COVID-19 – Coronavirus State and Local Fiscal Recovery Funds - ALN 21.027 Material Weakness in Internal Controls Over Compliance Criteria: Per 2 CFR section 200.214, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Condition: Suspension and debarment compliance was not verified for three covered transactions. Cause: Lack of appropriate oversight resulted in required suspension and debarment checks not being performed. Effect: Grant transactions are not supported adequately, and the Town is at risk of awarding contracts to vendors not eligible to participate in federal awards programs. It was determined that none of the three vendors were suspended or debarred from federal awards. Questioned Costs: None Repeat Finding from Prior Year: No. Recommendation: The Town should implement procedures to document that all contractors under covered transactions that are performing services for the grant are not suspended or debarred. Views of Responsible Official: Management agrees with the finding.
Finding Reference No.: 2024-001 Assistance Listing Number: 21.027 Program Title: COVID-19 - Coronavirus State and Local Fiscal Recovery Fund Finding: Suspension & Debarment Questioned Costs: Not Applicable Criteria: Title 2 U.S. Code of Federal Regulations Part 200.214 Suspension and Debarment states recipients and subrecipients are subject to the debarment and suspension regulations described in 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 Town did not provide evidence to support verification that entities were not suspended or debarred was performed. Cause: The Town does not have procedures and/or policies in place regarding verification for suspended or debarred entities. Effect: The Town may enter into contracts with entities that are suspended or debarred, which could result in noncompliance with federal requirements and the possibility of the reduction grant funding. Questioned Costs: No questioned costs were identified. Recommendation: We recommend the Town implement policies and procedures regarding verification of entity suspension and debarment. Repeat Finding: This is not a repeat finding. Views of Responsible Officials: See corrective action plan attached.
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.
NONCOMPLIANCE WITH PROCUREMENT, SUSPENSION & DEBARMENT REQUIREMENTS, CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS; AL No. 21.027, YEAR ENDED JUNE 30, 2024 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 1: The county did not verify that program recipients/participants were not suspended, debarred, or otherwise excluded from participation in the program. Condition 2: The county did not formally bid a communications upgrade pre-install project as required by federal procurement standards established in 2 CFR 300.19. Cause: The county does not have procurement policies and procedures in place that allows 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 Number, Federal Agency, and Program Name - ALN 21.027, Department of the Treasury, COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Award Identification Number and Year - SLFRP 2024-2001 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 180.300 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 complied with the above regulations. Questioned Costs - None Identification of How Questioned Costs Were Computed - Not applicable Context - Recipients of federal awards must have procedures in place to verify that a contractor with which they plan to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Cause and Effect - The City did not have a procedure in place to review contractors and entered into covered agreements without knowing whether the contractors were debarred, suspended, or otherwise excluded. Recommendation - We recommend that an additional internal process be put in place to ensure all vendors utilized with federal funds are not suspended or debarred. Views of Responsible Officials and Corrective Action Plan - The City will ensure that all future contracts awarded under this program are in compliance and will have contractors sign to verify that they are in compliance.
2024-001: Suspension and Debarment Program: Child and Adult Care Food Program (ALN 10.558) Federal agency: U.S. Department of Agriculture Pass-through entity name and identifying number: Maryland State Department of Education (347105) District of Columbia OSSE (N/A) Virginia Department of Health (4108) Federal Award Year: Year ended June 30, 2024 Program: Commodity Supplemental Food Program (ALN 10.565)(Food Distribution Cluster) Federal agency: U.S. Department of Agriculture Pass-through entity name and identifying number: District of Columbia Department of Health (CHA2022-000027) Montgomery County Department of Health and Human Services (1087608) Maryland Department of Aging (N/A) Federal Award Year: Year ended June 30, 2024 Program: Emergency Food Assistance Program (Administrative Costs) (ALN 10.568)(Food Distribution Cluster) Federal agency: U.S. Department of Agriculture Pass-through entity name and identifying number: Virginia Department of Agriculture and Consumer Services (VDACS) (67-150) District of Columbia OSSE Wellness and Nutrition Services Division (CW102461) District of Columbia Department of Health (N/A) Maryland Department of Human Resources Family Investment Administration (FIA/FNS 23-012-FY23 and FIA/FNS 23-012-FY 24) Federal Award Year: Year ended June 30, 2024 Program: Emergency Food Assistance Program (Commodities) (ALN 10.569)(Food Distribution Cluster) Pass-through entity name and identifying number: District of Columbia OSSE Wellness and Nutrition Services Division (CW102461) District of Columbia Department of Health (N/A) Virginia Department of Agriculture and Consumer Services (VDACS) (67-150) Maryland Department of Human Resources Family Investment Administration (FIA/FNS 23-012) Federal agency: U.S. Department of Agriculture Federal Award Year: Year ended June 30, 2024 Program: COVID-19: Coronavirus State and Local Recovery Funds (ALN 21.027) Federal agency: U.S. Department of the Treasury Pass-through entity name and identifying number: Federation of Virginia Food Banks (N/A) Federation of Virginia Food Banks – Farms to Families Box Program (N/A) Fairfax County (#SR-003432J) D.C. Department of Health (CHA2022-000020-1) Office of the Deputy Mayor for Planning and Economic Development (PO690289-FY23-DMPED) City of Falls Church (N/A) VA Department of Agricultural Services (2022-4A1-001) Prince William County (N/A) Federal Award Year: Year ended June 30, 2024 Type of finding: Material Weakness in Internal Control over Compliance Criteria: As stated in 2 CFR 200.214 Suspension and debarment, 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. As noted in 2 CFR 180.155, this verification may be accomplished by checking the System for Award Management (SAM.gov) exclusions to determine whether a person is excluded. 2 CFR 180.220(b)(1) indicates that contracts for goods or services where the amount is expected to equal or exceed $25,000 are covered transactions for the suspension and debarment requirement. Condition: We noted that, although CAFB has a written process for checking suspension and debarment, CAFB did not have documentation of a suspension and debarment check on procurements greater than $25,000 that we selected for testing in three major programs. Cause: The review process related to suspension and debarment did not occur as intended. Effect: Although not found in our testing, procurements could have been made to suspended or debarred parties. Context: Applies to controls over ensuring vendors are properly vetted and are not suspended or debarred. Questioned costs: None Repeat finding: No Recommendation: We recommend that the organization ensure the written procedures around suspension and debarment are followed. Views of responsible officials: CAFB has reviewed and agrees with the finding and the recommendation.
2024-001: Suspension and Debarment Program: Child and Adult Care Food Program (ALN 10.558) Federal agency: U.S. Department of Agriculture Pass-through entity name and identifying number: Maryland State Department of Education (347105) District of Columbia OSSE (N/A) Virginia Department of Health (4108) Federal Award Year: Year ended June 30, 2024 Program: Commodity Supplemental Food Program (ALN 10.565)(Food Distribution Cluster) Federal agency: U.S. Department of Agriculture Pass-through entity name and identifying number: District of Columbia Department of Health (CHA2022-000027) Montgomery County Department of Health and Human Services (1087608) Maryland Department of Aging (N/A) Federal Award Year: Year ended June 30, 2024 Program: Emergency Food Assistance Program (Administrative Costs) (ALN 10.568)(Food Distribution Cluster) Federal agency: U.S. Department of Agriculture Pass-through entity name and identifying number: Virginia Department of Agriculture and Consumer Services (VDACS) (67-150) District of Columbia OSSE Wellness and Nutrition Services Division (CW102461) District of Columbia Department of Health (N/A) Maryland Department of Human Resources Family Investment Administration (FIA/FNS 23-012-FY23 and FIA/FNS 23-012-FY 24) Federal Award Year: Year ended June 30, 2024 Program: Emergency Food Assistance Program (Commodities) (ALN 10.569)(Food Distribution Cluster) Pass-through entity name and identifying number: District of Columbia OSSE Wellness and Nutrition Services Division (CW102461) District of Columbia Department of Health (N/A) Virginia Department of Agriculture and Consumer Services (VDACS) (67-150) Maryland Department of Human Resources Family Investment Administration (FIA/FNS 23-012) Federal agency: U.S. Department of Agriculture Federal Award Year: Year ended June 30, 2024 Program: COVID-19: Coronavirus State and Local Recovery Funds (ALN 21.027) Federal agency: U.S. Department of the Treasury Pass-through entity name and identifying number: Federation of Virginia Food Banks (N/A) Federation of Virginia Food Banks – Farms to Families Box Program (N/A) Fairfax County (#SR-003432J) D.C. Department of Health (CHA2022-000020-1) Office of the Deputy Mayor for Planning and Economic Development (PO690289-FY23-DMPED) City of Falls Church (N/A) VA Department of Agricultural Services (2022-4A1-001) Prince William County (N/A) Federal Award Year: Year ended June 30, 2024 Type of finding: Material Weakness in Internal Control over Compliance Criteria: As stated in 2 CFR 200.214 Suspension and debarment, 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. As noted in 2 CFR 180.155, this verification may be accomplished by checking the System for Award Management (SAM.gov) exclusions to determine whether a person is excluded. 2 CFR 180.220(b)(1) indicates that contracts for goods or services where the amount is expected to equal or exceed $25,000 are covered transactions for the suspension and debarment requirement. Condition: We noted that, although CAFB has a written process for checking suspension and debarment, CAFB did not have documentation of a suspension and debarment check on procurements greater than $25,000 that we selected for testing in three major programs. Cause: The review process related to suspension and debarment did not occur as intended. Effect: Although not found in our testing, procurements could have been made to suspended or debarred parties. Context: Applies to controls over ensuring vendors are properly vetted and are not suspended or debarred. Questioned costs: None Repeat finding: No Recommendation: We recommend that the organization ensure the written procedures around suspension and debarment are followed. Views of responsible officials: CAFB has reviewed and agrees with the finding and the recommendation.