Finding Text
Assistance Listing Number and Program: 21.027 COVID-19 State and Local Fiscal Recovery Funds
Federal Agency: U.S. Department of Treasury
Pass-Through Entity and Award Number: Wisconsin Public Service Commission / 5-BF-2022
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 or 3) adding certification language to the contract or subaward with the entity. Additionally, per the agreement with the Wisconsin Public Service Commission, the nonfederal entity should, to the greatest extent practicable under the award, ensure the purchase or use of materials that are produced in the United States.
Condition: The Reedsburg Utility Commission (RUC) was not able to provide evidence that the suspension and debarment verification was completed or preference for the purchase of domestic materials for the two vendors selected for testing. The sample was not statistically valid.
Cause: The utility commission did not retain documentation that showed the search on SAM.gov and the preference of domestic material purchases was completed
Effect: Payments could be made to an entity that is on the suspended or debarred list or for materials that were not domestically sourced.
Questioned Costs: None reported.
Recommendation: The utility commission 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, and verifying that material purchase agreements are with domestic vendors, and retain documentation showing verification for these were done.
Management's Response: When purchasing inventory materials that may be used in the ARPA projects, RUC purchasing staff will request certification from the vendor that they are not suspended or debarred from federally funded projects and also request material country of origin documentation or Build America, Buy America (BABA) qualifications when receiving quotes.