Finding 1127964 (2024-101)

Assistance Listings number and name: 21.027 COVID-19 Coronavirus State and Local Fiscal Recovery Funds Award number and year: SLFRP0665, March 3, 2021 through December 31, 2026 Federal agency: U.S. Department of the Treasury Compliance requirement: Suspension and debarment Questioned costs: None Condition—Contrary to federal regulations, the County did not maintain documentation that it had verified 5 of 9 vendors we tested were not suspended or debarred from doing business with the federal government prior to making the purchases. The vendors were paid program monies totaling $740,467, or 49 percent of the program’s total federal award expenditures of $1.5 million. Effect—As the County could not demonstrate that at the time of the purchases it obtained services from vendors that had not been suspended or debarred from doing business with the federal government, the County was at increased risk that it could have paid federal program monies to unallowable vendors. Subsequently, we performed additional audit procedures and verified the vendors had not been suspended or debarred by the federal government. Finally, the County is at risk that this finding applies to other federal programs it administers. Cause—The County had informal procedures that were not consistently applied and lacked policies and procedures to verify that vendors, including those procured by the State of Arizona or through cooperative agreements, were not suspended or debarred from doing business with the federal government each year and to maintain documentation of this verification within the procurement files. Criteria—Federal regulations require the County to verify that vendors being paid more than $25,000 in federal program monies have not been suspended or debarred by either checking their suspension and debarment status, obtaining the vendor’s certification stating they are not suspended or debarred, and/or adding a condition regarding suspension and debarment to the purchase contract with the vendor (2 CFR §180.300). Also, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that the federal program is being managed in compliance with all applicable laws, regulations, and award terms (2 CFR §200.303). Recommendations—The County should: 1. Verify and maintain documentation that a vendor being paid more than $25,000 in federal program monies has not been suspended or debarred from doing business with the federal government. 2. Develop policies and procedures and train staff to: a. Verify the vendor’s suspension and debarment status prior to making purchases by examining the federal government’s sam.gov website, obtaining certification from the vendor, or adding a condition in the vendor contract. b. Maintain documentation of this verification within the procurement files.