Finding Text
Assistance Listing, Federal Agency, and Program Name ALN 21.027, Department of the Treasury, COVID 19 Coronavirus State and Local Fiscal Recovery Fund
Federal Award Identification Number and Year SLFRP2024 2001
Pass through Entity Not applicable
Finding Type Material weakness and material noncompliance with laws and regulations
Repeat Finding Yes
2023 002
Criteria Per 2 CFR 200.214 non federal entities are subject to the non procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, as well as 2 CFR part 180. The regulations in 2 CFR part 180 restrict making Federal awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in Federal awards.
Condition The City could not provide evidence that it performed a check to verify vendors or subrecipients were not suspended or debarred.
Questioned Costs None
Identification of How Questioned Costs Were Computed Not applicable
Context During the fiscal year, the City entered into contracts/agreements with 11 contractors and subrecipients. and was unable to provide evidence that the check for suspension and debarment was completed prior to entering into a contract/agreement with them. Subsequently, the City did complete the search on Sam.gov and retained evidence to support that the contractor was not suspended of debarred, thereby creating no questioned costs.
Cause and Effect The City did not have controls to perform the search for suspended or debarred entities prior to entering into a contract or subrecipient agreement, as a result the City did not comply with the requirements under 2 CFR 214.
Recommendation We recommend the City implement controls to ensure that complete the search for whether a contractor/subrecipient is suspended or debarred prior to entering into a contract/agreement with a contractor or subrecipient and retain evidence of the results of the search.
Views of Responsible Officials and Corrective Action Plan The City of Port Huron will implement a new process for approval of all invoices related to ARPA grant expenses. This includes a check for suspension and debarment prior to any invoices approval and appropriate documentation.