Finding 1116071 (2024-002)

Federal Agency: U.S. Department of Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) Assistance Listing Number: 21.027 Type of Finding: Significant Deficiency in Internal Control Over Compliance Criteria: According to § 180.300 of Subpart C - Responsibilities of Participants Regarding Transactions Doing Business with Other Persons of 2 CFR Part 180, when you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Condition: The County did not follow suspension and debarment regulation and suspension and debarment verification procedures. Questioned Costs: None Context: We selected 8 samples as part of our testing over Suspension and Disbarment. Of the 8 samples selected, the County was unable to provide proof of suspension and disbarment checks. Cause: The County has policies that require that the departments verify vendors through Sam.gov prior to entering transactions. However, the policy does not include documentation of these checks. Effect: Without checking debarment before engaging in services, the County could have entered into an agreement with a vendor that was disbarred from receiving federal funding. Repeat Finding: No Recommendation: We recommend that the County should implement procedures to ensure that federal guidance is followed relating to suspension and disbarment and to provide training on these procedures, which should include maintaining documentation of the review performed by the County. View of Responsible Officials: There is no disagreement with the audit finding.