Finding 1079784 (2023-005)

Significant Deficiency
Requirement
I
Questioned Costs
-
Year
2023
Accepted
2024-10-22
Audit: 325493
Organization: City of Montebello (CA)

AI Summary

  • Core Issue: The City failed to verify vendor suspension and debarment status before awarding contracts for federally funded projects.
  • Impacted Requirements: Compliance with federal regulations requiring checks against the SAM database prior to entering contracts.
  • Recommended Follow-Up: Update purchasing policies and procedures to ensure proper verification of vendor status and maintain documentation for all procurements.

Finding Text

Finding 2023-005 Internal Control Over Suspension and Debarment Identification of the Federal Programs: Assistance Listing Number: 20.507 Assistance Listing Title: Federal Transit Cluster Federal Agency: U.S. Department of Transportation Pass-Through Entity: N/A Federal Award Identification Number: CA-2017-149-00; CA-90-Z085-00; CA-90-Y974-00; CA -2019- 033-00; CA -90-Y900-00; CA-2020-177-00; CA-2021-169-01; CA-2022-041-00; CA-2021-075-00 Assistance Listing Number: 21.207 Assistance Listing Title: Coronavirus State and Local Fiscal Recovery Funds (“CSLFRF”) Federal Agency: U.S. Department of Treasury Pass-Through Entity: N/A Federal Award Identification Number: N/A Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Prior to entering into subawards and contracts with award funds, recipients must ensure that contractors and subcontractors are not suspended from participating in federally funded projects. Verification is typically done by reviewing the System for Award Management (“SAM”) database and including certifications in contacts. Condition: During the audit over suspension and debarment, we noted that there were no documentation on whether the vendors were checked against the SAM database or obtained required certifications before contract awards. Cause: There were no formal policies or procedures of the verification on the suspension and debarment status of vendors before entering into a federally funded contract. Effect or Potential Effect: Without verifying whether vendors are suspended or debarred from working on federally-funded projects prior to the contract being awarded, the City could be contracting with vendors that are prohibited from working on federally funded projects and incurring potentially disallowed costs. Questioned Costs: None noted. Context: See condition above for the context of the procurement finding. No support was provided for 6 out of 6 Federal Transit Cluster vendors selected for testing and 3 out of the 3 CSLFRF vendors selected for testing to show suspension and debarment check was performed prior to contracting. Identification as a Repeat Finding, If Applicable: Not applicable. Recommendation: We recommended the City update its purchasing policies and related procedures related to suspension and debarment to improve its internal control over compliance for suspension and debarment. Views of Responsible Officials: The City has implemented a new review, tracking and documentation process for all procurements. Staff will check all vendors -- regardless of the nature of the funding for the project – against SAM.GOV to check for disbarment. A PDF of the results for each vendor is saved in a project folder attached to each procurement. These files are stored on an internal network drive.

Categories

Procurement, Suspension & Debarment Subrecipient Monitoring

Other Findings in this Audit

  • 503330 2023-006
    Material Weakness Repeat
  • 503331 2023-006
    Material Weakness Repeat
  • 503332 2023-004
    Significant Deficiency Repeat
  • 503333 2023-004
    Significant Deficiency Repeat
  • 503334 2023-004
    Significant Deficiency Repeat
  • 503335 2023-004
    Significant Deficiency Repeat
  • 503336 2023-004
    Significant Deficiency Repeat
  • 503337 2023-006
    Material Weakness Repeat
  • 503338 2023-005
    Significant Deficiency
  • 503339 2023-005
    Significant Deficiency
  • 503340 2023-005
    Significant Deficiency
  • 503341 2023-005
    Significant Deficiency
  • 503342 2023-005
    Significant Deficiency
  • 503343 2023-005
    Significant Deficiency
  • 503344 2023-006
    Material Weakness Repeat
  • 1079772 2023-006
    Material Weakness Repeat
  • 1079773 2023-006
    Material Weakness Repeat
  • 1079774 2023-004
    Significant Deficiency Repeat
  • 1079775 2023-004
    Significant Deficiency Repeat
  • 1079776 2023-004
    Significant Deficiency Repeat
  • 1079777 2023-004
    Significant Deficiency Repeat
  • 1079778 2023-004
    Significant Deficiency Repeat
  • 1079779 2023-006
    Material Weakness Repeat
  • 1079780 2023-005
    Significant Deficiency
  • 1079781 2023-005
    Significant Deficiency
  • 1079782 2023-005
    Significant Deficiency
  • 1079783 2023-005
    Significant Deficiency
  • 1079785 2023-005
    Significant Deficiency
  • 1079786 2023-006
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
21.027 Coronavirus State and Local Fiscal Recovery Funds $4.61M
16.922 Equitable Sharing Program $530,930
21.016 Equitable Sharing $361,970
20.507 Federal Transit Formula Grants $335,301
14.218 Community Development Block Grants/entitlement Grants $116,640
10.559 Summer Food Service Program for Children $68,162
14.239 Home Investment Partnerships Program $63,458
20.205 Highway Planning and Construction $20,048