Finding 1100556 (2024-001)

2024 – 001 Suspension and Disbarment Federal Agency: U.S. Department of Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Significant Deficiency in Internal Control Criteria or Specific Requirement: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Before entering into a covered transaction, the entity must verify that the contractor is not suspended, disbarred, or otherwise excluded from participating in the transaction. Condition: Through our testing we noted that the City was not able to provide documentation supporting suspension and disbarment checks performed for seven vendors. Questioned Costs: None noted. Context: CLA reviewed eight vendors and for seven vendors, proof of suspension and disbarment checks were not available for review. Cause: The City's policies require that departments verify vendors through sam.gov prior to entering into transactions. However, the policy does not include documentation of these checks. Effect: Without checking debarment before engaging services, the City could have entered into an agreement with a vendor that was disbarred from receiving federal funding. Repeat Finding: This is not a repeat finding. Recommendation: CLA recommends the City implement procedures to ensure that federal guidance is followed relating to suspension and disbarment and provide training on these procedures, including maintaining documentation of the reviews performed by the City. Views of responsible officials: There is no disagreement with the audit findings.