Finding 1102832 (2024-002)

Finding No. 2024-002 - Procurement, Suspension and Debarment - Significant Deficiency Name of Federal Agency: U.S Department of the Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: Identification number unavailable. Program year 2024 Name of Pass-through Entity (if applicable): The Community Economic Development Assistance Corporation, the City of Brockton and the Plymouth County Commissioners. Criteria: In accordance with §200.318(a), General Procurement Standards, a nonfederal entity must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations, provided that the procurements conform to applicable federal law and the standards identified in General Procurement Standards. Additionally, §200.318(i) states that the nonfederal entity must maintain records sufficient to detail the history of the procurement. In addition, in accordance with §200.213 and §180.300, nonfederal entities cannot enter into awards, subawards, or contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Condition/Context: For 2 procurement samples out of a total of 2 tested, management did not provide adequate supporting documentation for the procurement including ensuring proper suspension and debarment checks were performed. Cause: The Agency did not have adequate policies, procedures, and controls in place to ensure compliance with the general procurement standards and suspension and debarment requirements. Effect or Potential Effect: Failure to perform procurement procedures in accordance with a written policy that complies with the Uniform Guidance could result in the procurement being disallowed. Failure to timely verify that a vendor is not suspended or debarred could result in entering into a contract with an entity that is barred from performing work for the U.S. government. Questioned Costs: None Identification as a Repeat Finding: This is a repeat finding (see prior year finding number: 2023- 002). Recommendation: We recommend that the Agency establish written procurement policies and procedures to ensure that the Agency is in compliance with the Uniform Guidance and that all staff are trained on this policy to ensure compliance and related internal controls over compliance are operating effectively. Views of Responsible Officials: Management agrees with the finding and is in the process of revising internal controls to address procurement, suspension and debarment requirements. Additionally, management has retroactively performed this requirement to the applicable transactions during the audit period, noting no vendors were suspended or debarred.