Finding Text
Finding 2024-002
Significant Deficiency: Procurement and Suspension and Debarment - Control Finding
ALN: 21.027 - Coronavirus State and Local Fiscal Recovery Funds
Federal Agency: U.S. Department of the Treasury
Pass-Through Entity: Missouri Department of Social Services
Criteria or Specific Requirement:
According to Uniform Guidance, 2 CFR Section 180.300, non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity.
Condition:
We noted through procedures performed that management did not maintain documentation to support whether or not a suspension or debarment verification was performed prior to entering into covered transactions with entities. In addition, a certification was not obtained from the entities nor was a clause added to the contract.
Cause:
Internal controls over compliance put in place by management were not designed effectively to ensure evidence of the SAM verification was maintained.
Effect:
The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance relating to reporting.
Questioned Costs:
Not applicable.
Context:
An exception was noted in the two covered vendor transactions sampled out of the population of four. The vendors tested in the transactions sampled were not suspended or debarred. Statistical sampling was not used to test this compliance requirement.
Identification as a Repeat Finding:
Not applicable.
Recommendation:
We recommend that management amend its procurement policy to require a SAM verification is performed prior to entering into contracts or covered transactions.
Views of Responsible Officials:
St. Patrick Center will update the agency procurement policy requiring a SAM verification for any vendors that receive contracts or are to be used in covered transactions.