Finding Text
2024-003
Federal Agency: Department of Treasury
Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds
Assistance Listing Number: 21.027
Federal Award Identification Number and Year: 1505-0271 - 2021
Award Period: March 3, 2021 – December 31, 2024
Type of Finding: Significant Deficiency in Internal Control Over Compliance
Criteria or specific requirement:
Compliance: 2 CFR 200.214 Suspension and Debarment restricts 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.
2 CFR 180.300 states that an entity may determine suspension and debarment status by:
(a) Checking SAM (System for Award Management) Exclusions; of
(b) Collecting a certification from that person; or
(c) Adding a clause of condition to the covered transaction with that person.
Controls: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective
internal control over the Federal award that provides reasonable assurance that the non-Federal entity
is managing the Federal award in compliance with Federal statutes, regulations, and the terms and
conditions of the Federal award. These internal controls should comply with guidance in “Standards for
Internal Control in the Federal Government” issued by the Comptroller General of the United States or
the ”Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of
the Treadway Commission (COSO).
Condition:
The Town did not determine the suspension and debarment status of vendors with expenditures
exceeding $25,000 on a timely basis, as required by federal regulations.
Questioned Cost: None
Context:
Four of the Five vendors we selected for testing had the suspension and debarment status verified,
however it was not performed timely.
Cause:
The Town’s procedures and internal controls over suspension and debarment are not sufficient to
ensure that all vendors’ suspension and debarment status is verified timely.
Effect:
Failure to verify the suspension and debarment status of vendors may result in the Town issuing
payments to vendors what are suspended and debarred and not authorized to provide services under
the program.
Repeat Finding: Yes, Finding 2023-003
Recommendation:
We recommend management ensure policies and procedures include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to issuance of the contract.
View of responsible officials and planned corrected actions:
Management concurs with this finding. Management has implemented a policy going forward to ensure all vendors entered into a contract will sign a suspension and debarment agreement.