Finding Text
2023 – 004: Suspension and Debarment
Federal Agency: U.S. Department of Treasury
Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds
Assistance Listing Number: 21.027
Federal Award Identification Number and Year: SLFRP1108 - 2021
Award Period: July 1, 2022, to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance
Criteria or Specific Requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost
Principles, and Audit Requirements for Federal Award requires compliance with the provisions of
procurement, suspension, and debarment. The City should have internal controls designed to ensure
compliance with those provisions.
Condition: The City was unable to provide evidence that suspension and debarment verification was
performed.
Questioned Costs: None
Context: 2 of 5 there was no SAM.gov check available and no certification of non-debarment on a
contract with the vendor. For 1 of 5 there was a SAM.gov check available, yet there was no evidence of
when the check took place.
Cause: Procedures were not in place to retain evidence of debarment status check, and when the
check took place.
Effect: The City is unable to provide evidence that internal control procedures over suspension and
debarment compliance were performed in a timely manner.
Repeat Finding: No
Recommendation: We recommend that the City add a section to its standard contractor and
subrecipient contracts for the other party to certify they are not suspended or otherwise debarred. In
addition, internal controls should be updated to ensure that evidence of the performance of suspension
and debarment compliance is retained for future reference.
Views of Responsible Officials: In response to the audit finding regarding the suspension and
debarment status for all vendors before contract execution, we have communicated with all relevant
staff on the importance of conducting debarment status checks prior to procurement and the
requirement of SAM.gov check, with date noted as verification of the check, and evidence be saved in
the contract file or the requirement that a certification of non-debarment status clause be included in
contracts.
To ensure ongoing compliance, we have instituted regular internal audits to verify SAM.gov checks are
being conducted and properly documented for all contracts.