Finding Text
2024 – 003 Suspension and Debarment
Federal agency: U.S. Department of Treasury
Federal program title: Coronavirus State and Local Fiscal Recovery Funds
Assistance Listing Number: 21.027
Federal Award Identification Number and Year: N/A
Award Period: March 3, 2021 – December 31, 2026
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
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. Nonfederal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a nonprocurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220).
Condition: The Village did not maintain records the vendor was not suspended or debarred prior to entering into the transactions.
Questioned costs: None
Context: 5 of 5 tested for suspension and debarment documentation.
Cause: The processes for suspension and debarment were not properly followed during the current fiscal year. Proper documentation was not retained. Village policies have not been updated yet.
Effect: May result in disallowed cost if grant requirements are not followed.
Repeat finding: This is a repeat finding. Prior year finding number was 2023-003.
Recommendation: We recommend the Village carefully review federal suspension and debarment requirements for proper documentation needed. The Village should consider use of a Federal procurement checklist.
Views of responsible officials: There is no disagreement with the audit finding.