Finding 1106553 (2024-001)

FINDING 2024-001 – SIGNIFICANT DEFICIENCY- PROCUREMENT AND SUSPENSION AND DEBARMENT- INTERNAL CONTROL OVER VERIFICATION AGAINST THE SYSTEM FOR AWARD MANAGEMENT (“SAM”) Federal Agency: Department of the Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Pass-Through Agency: State of Connecticut Office of Policy and Management Pass-Through Number(s): 12060-OPM20600-29669 Compliance Requirement: Procurement and Suspension and Debarment Criteria 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (Uniform Guidance) requires compliance with provisions of procurement, suspension, and debarment. Non-federal entities are required to ensure that they do not award contracts or make subawards to any parties that are suspended or debarred from receiving federal funds. This verification may be accomplished by checking the System for Award Management (SAM). Condition The Town does not have a process in place to check that vendors are not suspended or debarred by checking the System for Award Management (SAM). Context There was no process in place to verify that vendors are not suspended for debarred, however, none of the vendors selected for testing were suspended or debarred. Cause The Town’s procurement and compliance procedures did not include a process for checking and verifying suspension and debarment status of vendors at the time of award or at periodic intervals afterwards. Effect Failure to verify suspension and debarment status of parties engaged in federal transactions may result in noncompliance with federal regulations, leading to the risk of making awards to ineligible parties. Recommendation We recommend that the Town establish and implement policies and procedures to ensure compliance with suspension and debarment requirements. The Town should establish procedures to verify, prior to awarding any federal contract or subaward, that the vendor, contractor, or subrecipient is not listed on the SAM exclusions list or any other relevant suspension and debarment lists. Implement a periodic review process to ensure that current vendors, contractors, and subrecipients remain eligible and are not suspended or debarred. Document that the verification process was performed and maintain supporting documentation. Views of Responsible Officials and Planned Corrective Actions The Town will establish policies and procedures to ensure vendors are not suspended or debarred by checking the System for Award Management (SAM) and maintain documentation showing that verification.