Finding Text
CONDITION: Per the on-site monitoring report of the City’s Community Development Block Grant (CDBG) Program performed by the Department of Housing and Urban Development dated May 15, 2024, the City purchased a device called ShotSpotter with CDBG contract B-20-MC-42-0106 funding in the amount of $99,000. The City of McKeesport did not verify if the above vendor was on the excluded parties list in the System for Award Management through www.sam.gov.
CRITERIA: In accordance with Section 2 CFR 200.214 of the Uniform Guidance, the District is subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict the awarding of contracts to certain parties that are debarred, suspended, or otherwise ineligible to participate in federal assistance programs. In addition, the City’s Community Development Block Grant Policies & Procedures Manual in Section VIII for procurement requires this step to be performed.
CAUSE: It was not readily determinable as to why this procedural step was overlooked by applicable City personnel during the procurement process.
EFFECT: The City of McKeesport did not comply with the requirements of Section 2 CFR 200.214 of the Uniform Guidance, nor Section VIII of the City’s CDBG Policies & Procedures Manual for procurement, regarding the procedure required to determine whether a contractor/vendor was debarred or suspended from participating in federal assistance programs.
QUESTIONED COST: $99,000
RECOMMENDATION: I am recommending that the management of the City utilize the www.sam.gov website for determining whether contractors/vendors are debarred or suspended from participating in federal assistance programs on all future applicable contract awards to ensure compliance with Section 2 CFR 200.214 of the Uniform Guidance, and Section VIII of the City’s CDBG Policies & Procedures Manual for procurement.
VIEWS OF RESPONSIBLE OFFICIALS: The City concurs with the above noted finding and addresses this issue in the ‘Corrective Action Plan’ included within this report.