Finding 1075180 (2023-004)

Finding 2023-004 Program ALN: 21.027 Program Title: COVID-19 Coronavirus State and Local Fiscal Recovery Funds (SLFRF) Award Number/Year: Not applicable / 2023 Federal Agency: U.S. Department of Treasury Criteria: Per 2 CFR Part 180, when a nonfederal entity enters into a procurement transaction with another entity for goods or services that equals or exceeds $25,000, also known as a covered transaction, the nonfederal entity must verify that the entity is not suspended or debarred. A nonfederal entity has three options for performing this verification: 1) obtaining a certification from the entity; 2) checking the System for Award Management (SAM) Exclusions (https://www.sam.gov/SAM/) or 3) adding certification language to the contract or subaward with the entity. Condition/Context: The County was not able to provide evidence that the suspension and debarment verification was completed for the three contractors selected for testing. The sample was not statistically valid. Cause: Due to turnover within the purchasing manager position, the verification was not completed. Effect: Payments could be made to an entity that is on the suspended or debarred list. Questioned Costs: None noted. Recommendation: The County should review its internal control procedures to ensure there are proper processes in place for verifying applicable procurement transactions are not entered into with a suspended or debarred entity. Management's Response: Training has been provided to the County’s Purchasing division regarding the requirement to review and record evidence that verification is completed on vendors prior to contracting.