Finding Text
FINDING 2024-001 – SIGNIFICANT DEFICIENCY- PROCUREMENT AND SUSPENSION
AND DEBARMENT- INTERNAL CONTROL OVER VERIFICATION AGAINST THE SYSTEM
FOR AWARD MANAGEMENT (“SAM”)
Federal Agency: Department of the Treasury
Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds
Assistance Listing Number: 21.027
Pass-Through Agency: State of Connecticut Office of Policy and Management
Pass-Through Number(s): 12060-OPM20600-29669
Compliance Requirement: Procurement and Suspension and Debarment
Criteria
2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit
Requirements for Federal Awards, (Uniform Guidance) requires compliance with provisions of
procurement, suspension, and debarment. Non-federal entities are required to ensure that
they do not award contracts or make subawards to any parties that are suspended or debarred
from receiving federal funds. This verification may be accomplished by checking the System
for Award Management (SAM).
Condition
The Town did not have a process in place to check that vendors were not suspended or
debarred by checking the System for Award Management (SAM).
Context
There was no process in place when the vendor selected during testing was awarded the
contract. Since that time, the Town has implemented new procedures to verify vendors going
forwards. None of the vendors selected for testing were suspended or debarred.
Cause
The Towns procurement and compliance procedures did not include a process for checking
and verifying suspension and debarment status of vendors at the time of award or at periodic
intervals afterwards.
Effect
Failure to verify suspension and debarment status of parties engaged in federal transactions
may result in noncompliance with federal regulations, leading to the risk of making awards to
ineligible parties.
Recommendation
We recommend that the Town establish and implement policies and procedures to ensure
compliance with suspension and debarment requirements. The Town should establish
procedures to verify, prior to awarding any federal contract or subaward, that the vendor,
contractor, or subrecipient is not listed on the SAM exclusions list or any other relevant
suspension and debarment lists. Implement a periodic review process to ensure that current
vendors, contractors, and subrecipients remain eligible and are not suspended or debarred.
Document that the verification process was performed and maintain supporting
documentation.
Views of Responsible Officials and Planned Corrective Actions
The Town has established policies and procedures since the vendor that was selected for
testing was awarded the contract to ensure vendors are not suspended or debarred by
checking the System for Award Management (SAM) and maintain documentation showing that
verification.