Finding 1098850 (2022-004)

Significant Deficiency
Requirement
I
Questioned Costs
-
Year
2022
Accepted
2025-02-07
Audit: 341682
Organization: City of Bloomington (IN)
Auditor: Crowe LLP

AI Summary

  • Core Issue: The City failed to verify that vendors funded by the CSLFRF were not suspended or debarred, leading to significant compliance deficiencies.
  • Impacted Requirements: Noncompliance with 2 CFR 180.300 regarding procurement and suspension/debarment checks for covered transactions.
  • Recommended Follow-Up: Establish internal controls to ensure compliance, including performing and documenting suspension and debarment checks before vendor transactions.

Finding Text

Information on the federal program: Federal Agency: Department of the Treasury Pass-Through Entity: N/A – Direct Grant Federal Program: Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) Assistance Listing Number: 21.027 Compliance Requirement: Procurement – Suspension and Debarment Audit Findings: Significant Deficiency, Noncompliance Criteria: 2 CFR 180.300 states: “When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: a) Checking the SAM Exclusions; or b) Collecting a certification from that person; or c) Adding a clause or condition to the covered transaction with that person.” Condition: The City could not provide documentation to support that vendors procured under CSLFRF funding were not suspended or debarred. Cause: The City had not developed a system of internal controls that would have ensured compliance with Procurement and Suspension and Debarment compliance requirements for covered transactions. Effect: The failure to establish internal controls could have enabled noncompliance to go undetected. If vendors would have been suspended or debarred, the failure to comply with the grant agreement and the compliance requirement could have resulted in the loss of federal funds to the City. Questioned costs: There are no questioned costs. Context: In a sample of six vendors with aggregate disbursements for the year ended December 31, 2022, above the $25,000 covered transaction threshold, Crowe noted four vendors that the City had not completed a check for suspension and debarment nor had they obtained a contract clause from the vendor/service provider certifying that they were not suspended and/or debarred. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: We recommend that the City establish and implement control procedures to ensure compliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. This should include ensuring suspension and debarment checks are performed and documented prior to entering into the transaction. Views of responsible officials and planned corrective actions: Management acknowledges the finding. See management’s corrective action plan attached to this audit report.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 522400 2022-005
    Significant Deficiency
  • 522401 2022-005
    Significant Deficiency
  • 522402 2022-005
    Significant Deficiency
  • 522403 2022-005
    Significant Deficiency
  • 522404 2022-005
    Significant Deficiency
  • 522405 2022-005
    Significant Deficiency
  • 522406 2022-002
    Material Weakness
  • 522407 2022-003
    Significant Deficiency
  • 522408 2022-004
    Significant Deficiency
  • 1098842 2022-005
    Significant Deficiency
  • 1098843 2022-005
    Significant Deficiency
  • 1098844 2022-005
    Significant Deficiency
  • 1098845 2022-005
    Significant Deficiency
  • 1098846 2022-005
    Significant Deficiency
  • 1098847 2022-005
    Significant Deficiency
  • 1098848 2022-002
    Material Weakness
  • 1098849 2022-003
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
21.027 Coronavirus State and Local Fiscal Recovery Funds $5.00M
16.034 Coronavirus Emergency Supplemental Funding Program $107,955
20.205 Highway Planning and Construction $78,510
14.218 Community Development Block Grants/entitlement Grants $66,994
16.922 Equitable Sharing Program $57,371
14.239 Home Investment Partnerships Program $46,631
16.738 Edward Byrne Memorial Justice Assistance Grant Program $32,193
15.611 Wildlife Restoration and Basic Hunter Education and Safety $23,389
84.287 Twenty-First Century Community Learning Centers $19,117
20.600 State and Community Highway Safety $14,173
10.559 Summer Food Service Program for Children $7,270
93.994 Maternal and Child Health Services Block Grant to the States $6,941
20.608 Minimum Penalties for Repeat Offenders for Driving While Intoxicated $3,228
14.469 United States Department of Housing and Urban Development $722