Finding 1096230 (2023-004)

Federal Agency: U.S. Department of Treasury Federal Program Title: State and Local Fiscal Recovery Funds Federal CFDA: 21.027 Pass-Through Agency: Direct Program Pass-Through Numbers: N/A Award Period: March 3, 2021 – December 31, 2026 Type of Finding: Material weakness in Internal Control Over Compliance Compliance Requirement: Procurement, Suspension & Debarment Criteria: Non-federal 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 non-procurement 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 County entered into a procurement transaction that exceeded the covered threshold and did not perform a search for suspension and debarment in accordance with 2 CFR section 180.220. Questioned Costs: None Context: The County did not perform a search for the one procurement transaction that exceeded the covered transaction threshold. Cause: The County departments were not aware of the requirements and did not have a procedure in place to perform a search for suspension and department associated for covered transactions. Effect: Certain vendors could be used that are considered suspended or debarred by the federal government resulting in noncompliance. Repeat Finding: Repeat of Finding 2022-003 Recommendation: We recommend that the County review its policies over suspension and debarment review to ensure they are maintaining compliance and controls over verifying or contracting with vendors that are allowable. Views of Responsible Officials: Refer to the management response per the corrective action plan.