Finding Text
Assistance Listing, Federal Agency, and Program Name - 20.500, 20.507, 20.525, 20.526, U.S. Department of Transportation, Federal Transit Cluster
Federal Award Identification Number and Year - All, including COVID 19
Pass through Entity - Not applicable
Finding Type - Material weakness and material noncompliance with laws and regulations
Repeat Finding - No
Criteria - The Organization should ensure there is a process in place, prior to entering into contracts with vendors in excess of $25,000, to verify such contractors are not suspended debarred, or otherwise excluded pursuant to 2 CFR Section 180.300.
Condition - There was no evidence to support that the Organization performed procedures to verify that the vendors were not suspended, debarred or otherwise excluded prior to entering into contracts in all instances.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - Not applicable
Context - Of the 60 procurements selected for testing, not all of the procurements contained evidence of either (1) a search performed on Sam.gov to determine if the vendor was suspended, debarred, or otherwise excluded; (2) a certification from the contractor attesting that they are not suspended, debarred, or otherwise excluded; or (3) adding a clause or condition to the covered transaction with that vendor.
Cause and Effect - The Organization has experienced turnover that resulted in the Authority being unable to locate documentation to support compliance.
Recommendation - We recommend that internal controls be put in place to ensure that the required verification is performed, documented and reviewed by a supervisor prior to entering into contracts with vendors.
Views of Responsible Officials and Planned Corrective Actions - Procurement manager is assigned responsibility for verifying and documenting that vendors were not suspended, debarred or otherwise excluded through Sam.gov. This has also been added to our current document checklist and will be part of the new accounting ERP automated procurement workflow and review process.