Finding Text
2023 – 003 Procurement and Suspension and Debarment
Federal Agency: U.S. Department Treasury
Federal Program Name: Coronavirus State and Local Fiscal Recovery Fund
Assistance Listing Number: 21.027
Federal Award Identification Number and Year: SLFRP3738 11/30/2021
Award Period: March 3, 2021 through December 31, 2024
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matter
Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.318, 2 CFR 200.319, 2 CFR 200.324, 2 CFR 180.220, and 2 CFR 200.320,) requires a non-federal entity to maintain records sufficient to detail the history of procurement, the providing of full and open competition, the performing of cost or price analysis, and prohibits the non-federal entity to contract or make subawards to parties that are suspended or debarred (covered transactions over $25,000). These records will include the rationale for the method of procurement, selection of contract type, contractor selection or rejection, the basis for the contract price, how full and open competition was provided, the cost or price analysis performed, and verification the vendor is not suspended or debarred through the SAMs exclusion list, collecting of certification from the entity, or by adding a clause or condition to the covered transaction with the entity. Procurement methods used must be appropriate based on the dollar amount and conditions specified.
Condition: Procurement methods for certain federal award purchases were not adequately documented or appropriately selected in accordance with the County’s procurement policy. In addition, the County did not maintain records the vendor was not suspended or debarred prior to entering into the transactions.
Questioned costs: Unknown
Context: 6 of 6 tested for procurement documentation and 6 of 6 tested for suspension and debarment documentation.
Cause: With new federal funding opportunities due to the pandemic, and new guidance related to those grants, proper documentation was not retained. County policies have not been updated yet.
Effect: May result in a disallowed cost if grant requirements are not followed.
Repeat Finding: This is a repeat finding. Prior year finding number was 2022-003.
Recommendation: We recommend the County carefully review federal procurement requirements for proper documentation needed. The County should consider use of a Federal procurement checklist.
Views of responsible officials: There is no disagreement with the audit finding.