Finding 1102322 (2023-006)

- Repeat Finding
Requirement
I
Questioned Costs
-
Year
2023
Accepted
2025-03-06
Audit: 345033
Organization: County of Solano (CA)
Auditor: Eide Bailly LLP

AI Summary

  • Core Issue: The County's purchasing policy lacks a requirement to verify vendor debarment and suspension status before contracts, leading to potential noncompliance.
  • Impacted Requirements: This violates 2 CFR part 200 and 31 CFR section 19.300, which mandate verification to ensure federal funds are not awarded to excluded parties.
  • Recommended Follow-Up: Update the purchasing policy to include vendor verification procedures, such as checking SAM registration or obtaining vendor certifications.

Finding Text

Program: Epidemiology and Laboratory Capacity for Infectious Diseases Federal Financial Assistance Listing No.: 93.323 Federal Agency: U.S. Department of Health and Human Services Passed-through: California Department of Public Health Award Number and Year: COVID-19ELC48, COVID-19ELC106, 2021/2022 Compliance Requirement: Procurement, Suspension and Debarment Type of Finding: Instances of Noncompliance Criteria: Per 2 CFR part 200, subpart D, section 200.303, the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award is compliance with federal statues, regulations, and the terms and conditions of the federal award. Prior to entering into subawards and contracts with award funds, recipients must verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded pursuant to 31 CFR section 19.300. Condition: We identified that the County’s purchasing and contracting policy does not require the verification of the debarment and suspension status of vendors prior to entering into agreements. Cause: The County is in process of updating its purchasing and contracting policy to include verifying the debarment and suspension status of vendors prior to entering into agreements through one of the permitted methods: verify SAM registration status of potential vendors, collect certification from potential vendors, or include a clause or condition to the contract. The County’s current purchasing and contracting policy does not require verification of the vendors debarment and suspension status. Effect: Noncompliance with these requirements could result in disbursement of Federal funds to suspended or debarred parties. Questioned Costs: None reported. Context/Sampling: The County’s purchasing and contracting policy utilized by the department does not include verification of vendor debarment and suspension status prior to entering in the agreement. Repeat Finding from Prior Year: Yes. See prior year finding 2022-010. Recommendation: We recommend that the County implement in its policies procedures to verify SAM registration status of potential vendors, collect certification from potential vendors, or include a clause or condition to the contract to verify that entities to which the County is awarding Federal funds is not suspended or debarred. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Categories

Procurement, Suspension & Debarment Subrecipient Monitoring

Other Findings in this Audit

  • 525869 2023-002
    Material Weakness Repeat
  • 525870 2023-002
    Material Weakness Repeat
  • 525871 2023-003
    Material Weakness Repeat
  • 525872 2023-003
    Material Weakness Repeat
  • 525873 2023-004
    - Repeat
  • 525874 2023-004
    - Repeat
  • 525875 2023-004
    - Repeat
  • 525876 2023-005
    Material Weakness Repeat
  • 525877 2023-005
    Material Weakness Repeat
  • 525878 2023-005
    Material Weakness Repeat
  • 525879 2023-006
    - Repeat
  • 525880 2023-006
    - Repeat
  • 525881 2023-006
    - Repeat
  • 525882 2023-007
    Material Weakness
  • 525883 2023-008
    Material Weakness
  • 525884 2023-008
    Material Weakness
  • 525885 2023-008
    Material Weakness
  • 1102311 2023-002
    Material Weakness Repeat
  • 1102312 2023-002
    Material Weakness Repeat
  • 1102313 2023-003
    Material Weakness Repeat
  • 1102314 2023-003
    Material Weakness Repeat
  • 1102315 2023-004
    - Repeat
  • 1102316 2023-004
    - Repeat
  • 1102317 2023-004
    - Repeat
  • 1102318 2023-005
    Material Weakness Repeat
  • 1102319 2023-005
    Material Weakness Repeat
  • 1102320 2023-005
    Material Weakness Repeat
  • 1102321 2023-006
    - Repeat
  • 1102323 2023-006
    - Repeat
  • 1102324 2023-007
    Material Weakness
  • 1102325 2023-008
    Material Weakness
  • 1102326 2023-008
    Material Weakness
  • 1102327 2023-008
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
93.563 Child Support Enforcement $7.68M
20.205 Highway Planning and Construction $3.38M
14.871 Section 8 Housing Choice Vouchers $3.13M
10.557 Special Supplemental Nutrition Program for Women, Infants, and Children $2.71M
93.778 Medical Assistance Program $2.36M
93.224 Consolidated Health Centers (community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) $1.73M
93.224 Covid-19 Consolidated Health Centers (community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) $1.31M
93.044 Special Programs for the Aging_title Iii, Part B_grants for Supportive Services and Senior Centers $826,610
21.027 Covid-19 Coronavirus State and Local Fiscal Recovery Funds $596,260
16.575 Crime Victim Assistance $593,209
93.659 Adoption Assistance $553,181
10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program $505,023
93.498 Covid-19 Provider Relief Fund $463,799
93.994 Maternal and Child Health Services Block Grant to the States $388,673
16.738 Edward Byrne Memorial Justice Assistance Grant Program $349,914
93.918 Grants to Provide Outpatient Early Intervention Services with Respect to Hiv Disease $341,429
20.608 Minimum Penalties for Repeat Offenders for Driving While Intoxicated $334,090
93.667 Social Services Block Grant $329,728
93.658 Foster Care_title IV-E $312,354
93.556 Promoting Safe and Stable Families $301,061
16.606 State Criminal Alien Assistance Program $298,259
93.052 National Family Caregiver Support, Title Iii, Part E $291,617
97.067 Homeland Security Grant Program $251,279
93.889 National Bioterrorism Hospital Preparedness Program $240,451
93.391 Activities to Support State, Tribal, Local and Territorial (stlt) Health Department Response to Public Health Or Healthcare Crises $226,463
93.045 Special Programs for the Aging_title Iii, Part C_nutrition Services $217,908
93.526 Covid-19 Affordable Care Act (aca) Grants for Capital Development in Health Centers $211,510
93.069 Public Health Emergency Preparedness $208,837
93.053 Nutrition Services Incentive Program $207,308
93.268 Immunization Cooperative Agreements $182,180
93.354 Covid-19 Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response $161,633
93.674 John H. Chafee Foster Care Program for Successful Transition to Adulthood $148,008
17.258 Wia Adult Program $139,508
93.645 Stephanie Tubbs Jones Child Welfare Services Program $134,957
20.616 National Priority Safety Programs $127,440
93.958 Covid-19 Block Grants for Community Mental Health Services $120,486
17.278 Wia Dislocated Worker Formula Grants $113,074
93.958 Block Grants for Community Mental Health Services $106,592
59.037 Small Business Development Centers $104,192
16.034 Covid-19 Coronavirus Emergency Supplemental Funding Program $97,487
93.090 Guardianship Assistance $85,194
93.116 Project Grants and Cooperative Agreements for Tuberculosis Control Programs $85,050
93.940 Hiv Prevention Activities_health Department Based $82,288
93.747 Elder Abuse Prevention Interventions Program $72,639
93.042 Special Programs for the Aging_title Vii, Chapter 2_long Term Care Ombudsman Services for Older Individuals $72,071
93.558 Temporary Assistance for Needy Families $71,379
14.879 Mainstream Vouchers $66,358
14.896 Family Self-Sufficiency Program $60,668
16.742 Paul Coverdell Forensic Sciences Improvement Grant Program $49,554
93.043 Special Programs for the Aging_title Iii, Part D_disease Prevention and Health Promotion Services $47,877
97.042 Emergency Management Performance Grants $46,060
15.605 Sport Fish Restoration Program $45,942
93.870 Maternal, Infant and Early Childhood Home Visiting Grant $43,042
17.277 Workforce Investment Act (wia) National Emergency Grants $42,869
93.590 Community-Based Child Abuse Prevention Grants $35,923
93.150 Projects for Assistance in Transition From Homelessness (path) $35,911
93.044 Covid-19 Special Programs for the Aging_title Iii, Part B_grants for Supportive Services and Senior Centers $25,037
17.259 Wia Youth Activities $25,003
93.917 Hiv Care Formula Grants $22,479
93.197 Childhood Lead Poisoning Prevention Projects_state and Local Childhood Lead Poisoning Prevention and Surveillance of Blood Lead Levels in Children $19,857
93.959 Block Grants for Prevention and Treatment of Substance Abuse $19,601
16.U02 Safe Streets Violent Crimes Initiative $17,387
16.U03 2022 Domestic Cannabis Eradication Suppression Program $15,381
10.025 Plant and Animal Disease, Pest Control, and Animal Care $15,079
93.323 Covid-19 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $6,795
93.603 Adoption Incentive Payments $6,196
93.052 Covid-19 National Family Caregiver Support, Title Iii, Part E $4,169
93.041 Special Programs for the Aging_title Vii, Chapter 3_programs for Prevention of Elder Abuse, Neglect, and Exploitation $3,144
93.747 Covid-19 Elder Abuse Prevention Interventions Program $2,171
93.042 Covid-19 Special Programs for the Aging_title Vii, Chapter 2_long Term Care Ombudsman Services for Older Individuals $1,562
16.U04 2023 Domestic Cannabis Eradication Suppression Program $1,435
20.106 Covid-19 Airport Improvement Program $527
93.566 Refugee and Entrant Assistance_state Administered Programs $195
93.045 Covid-19 Special Programs for the Aging_title Iii, Part C_nutrition Services $105