Finding Text
Funding Agency: U.S. Department of the Treasury
Federal ALN: 21.027
Criteria
Per OMB guidance, non-federal entities are prohibited from contracting with parties that are suspended or debarred, or whose principals are suspended or debarred.
Condition
The Chamber has a procurement policy in place; however, the Chamber neglected to verify if vendors had been suspended or debarred, in accordance with stated regulations.
Context
Per our review of vendors over the applicable threshold, there was no documentation of having been reviewed for suspension or debarment.
Cause
Staff claimed that they had been conducting business transactions with these vendors prior to having a procurement policy in place and did not implement the procurement policy on already developed business relationships.
Effect
Purchases may have occurred that do not follow the policy, and contracts to vendors that had been suspended or debarred could have been awarded and not detected.
Auditor's Recommendations
Tacoma-Pierce County Chamber of Commerce should include a provision in all contracts transacted in conjunction with using funds originating from a federal award grant, with respect to suspension and debarment, communicate all requirements for procurement to staff and establish procedures to verify that vendors are not suspended or debarred.