Finding Text
Finding 2023-001 - Procurement and Suspension, and Debarment - Internal Control over Verification
Against the System for Award Management (“SAM”)
Assistance Listing Program Title and Number- Coronavirus State and Local Fiscal Recovery Funds
21.027
Federal Agency- Department of Treasury
Pass-through Entity- State Office of Policy and Management, State Department of Education
Criteria or specific requirement:
2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for
Federal Awards, (Uniform Guidance) requires compliance with provisions of procurement, suspension,
and debarment.
Non-federal entities are prohibited from contracting with or making subawards under covered transactions
to parties that are suspended or debarred. When a non-federal 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:
During our audit, we noted that the Town did not have documentation to support that it verified vendors
selected for testing against the SAM to ensure that they were not suspended or debarred from federally—
funded purchases.
Cause:
While the Town has a formal policy requiring the purchasing department to perform verification of
suspension or debarment over vendors that the Town makes contracts with federally-funded projects, it
does not maintain formal documentation that this procedure occurred.
Effect:
Without documented evidence of verifying whether the Town was followings its policy, the Town could not
provide evidence of this control was being completed for federally-funded projects. There were no
standard forms or templates that were used to document verification that parties are not suspended or
debarred.
Questioned Cost:
None
Context:
See condition above for context for the finding. There was no documentation available for 13 out of 13
selections tested. However, none of the vendors selected for testing were suspended or debarred.
Repeating Finding:
No
Recommendation:
We recommend that the Town implement a policy to formally document the procedures they are
performing.
Views of responsible officials of the auditee:
The Town agrees with the finding and the recommendation.