Finding Text
2024-001
Federal Agency: U.S. Department of Treasury
Federal Program Name: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
Assistance Listing Number: 21.027
Pass-Through Agency: Massachusetts Department of Revenue
Pass-Through Number: ARPACNTYSH056
Award Period: July 1, 2023 – June 30, 2024
Type of Finding: Significant Deficiency in Internal Control Over Compliance
Compliance Requirement: Suspension and Debarment
Criteria or Specific Requirement: The Code of Federal Regulations (CFR) Title 2 Part 200.214 states
that nonfederal entities are subject to the nonprocurement debarment and suspension regulations
implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards,
subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded
from or ineligible for participation in Federal assistance programs or activities. Nonfederal entities must
verify that contracts with certain parties are not debarred, suspended, or otherwise excluded from or
ineligible for participation in Federal assistance programs or activities.
Condition and Context: For three vendors in our audit sample, the Town did not document verification
that the vendor was not suspended or debarred from participation in Federal assistance programs or
activities. The vendors in our audit sample were not suspended or debarred.
Questioned Costs: None.
Cause: Procedures were not in place to document the verification that all vendors were not suspended
or debarred from participation in Federal assistance programs or activities.
Effect: While this did not occur in the instances identified in this finding, lack of verification of vendors’
debarment or suspension status could cause federal grant funds to be expended with vendors that are
excluded from participation in Federal assistance programs or activities.
Repeat Finding: Yes (Finding 2023-001).
Recommendation: We recommend to annually (at a minimum) document the verification that all
vendors are not suspended or debarred from participation in Federal assistance programs or activities.
Views of Responsible Officials: Management agrees with the finding.