Finding Text
2023-003
Federal Grants Management - Procurement Policy – Suspension and Debarment
Federal Agency: Department of Treasury
Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds
Assistance Listing Number: 21.027
Federal Award Identification Number and Year: N/A
Pass-Through Agency: Michigan Department of Treasury
Award Period: March 1, 2021 – December 31, 2024
Type of Finding: Material Weakness in Internal Control over Compliance and Other Matter
Criteria or Specific Requirement: 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 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.
Condition: The County did not perform a search for suspension and debarment for vendors the County initiated procurement transactions in excess of $25,000.
Questioned Costs: None
Context: During our testing, it was noted on both items tested that Dickinson County, Michigan was not reviewing vendors prior to entering into a contract with a vendor to ensure the vendor was not on the suspended or debarred vendor list maintained by the General Services Administration.
Cause: The County was not aware of the requirements under suspension and debarment.
Effect: The County could contract with a vendor that has been suspended or debarred from receiving federal funds.
Repeat Finding: Repeat of Finding 2022-003
Recommendation: We recommend the County use sam.gov or the ELPS listing to review clients at the beginning of the year or before a transaction is incurred in accordance with Uniform Guidance requirements.
Views of Responsible Officials: There is no disagreement with the audit finding.