Finding 1054304 (2023-001)

Assistance Listing, Federal Agency, and Program Name 21.027, U.S. Department of Treasury, COVID 19 Coronavirus State & Local Fiscal Recovery Fund Federal Award Identification Number and Year 2023 Pass through Entity Not applicable Finding Type Material weakness and material noncompliance with laws and regulations Repeat Finding No Criteria Per 2 CFR 180.300, before entering into a covered transaction with another person, grant recipients must verify that the person with whom they intend to do business is not excluded or disqualified. This is done by (a) checking SAM exclusions, (b) collecting a certification from that person, or (c) adding a clause or condition to the covered transaction with that person. Condition The Corporation did not perform the suspension or debarment check for contractors, before entering into a contract with them Questioned Costs None Identification of How Questioned Costs Were Computed Not applicable Context The Corporation entered into various contract agreements with 13 contractors during the year without verifying whether they were excluded or disqualified prior to entering into the contracts. Cause and Effect Controls in place did not ensure the Corporation verified contractors paid were not excluded or disqualified prior to entering into transactions with the contractors. The Corporation did perform the check after the fact and noted that none of the 13 contractors were identified as excluded or disqualified, therefore creating no questioned costs. Recommendation We recommend the Corporation establish a procedure for checking for excluded or disqualified persons prior to entering into contract agreements. Further, we recommend a periodic review process be established to ensure the procedure is implemented timely.