FAC Explorer

Finding 1131254 (2024-001)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2024
Accepted
2025-04-11
Audit: 353379
Organization: City of Columbus, Ohio (OH)
Auditor: Ohio Auditor of State

AI Summary

  • Core Issue: The City of Columbus did not consistently verify vendor status against SAM exclusions before entering into covered transactions, risking payments to suspended or debarred entities.
  • Impacted Requirements: Compliance with 31 CFR 19.305(a) and internal policies requiring verification for transactions over $25,000.
  • Recommended Follow-Up: Ensure all departments adhere to verification procedures, maintain evidence of compliance, and update contract routing policies to include SAM.gov checks.

Finding Text

31 CFR 19.305(a) states that Non-Federal entities are prohibited from entering into a covered transaction with parties that are suspended or debarred or whose principals are suspended or debarred, unless the Federal agency responsible for the transaction grants an exception under 31 CFR § 19.120.31 CFR § 19.200 identifies “covered transactions” as non-procurement or procurement transactions at the primary tier, between a Federal agency and a person; or at the lower tier, between a participant in a covered transaction and another person. Procurement contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) are covered transactions if the contracts are expected to equal or exceed $25,000 or meet certain other specified criteria outlined in 31 CFR § 19.220. All non-procurement transactions (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless exempt by 31 CFR § 19.215.When a non-Federal entity enters into a covered transaction, the non-Federal entity must verify that the entity is not suspended or debarred or otherwise excluded. This verification may be accomplished by checking SAM exclusions (https://sam.gov); collecting a certification from the entity, or adding a clause or condition to the covered transactions with that entity. Furthermore, the City of Columbus Purchasing Policy Manual - Bid and Proposal Evaluations - Federal Grants - Special Instructions provides "each department will review its Federal grants program policies and procedures for contract routing and update them immediately to include the following: A SAM.gov website review shall be included as the first page with each original contract scanned into Dynamics 365."While the City does have an internal control policy in place regarding the SAM exclusion verifications of suspended or debarred entities, the City did not always adhere to the policy when entering into covered transactions. During testing of the AL #21.027 Coronavirus State and Local Fiscal Recovery Funds, we noted one out of seven instances (14%) in which the programs had a payment to a vendor of more than $25,000 and no evidence the City checked the SAM exclusions, collected a certification from the entity, or added a clause or condition to the covered transaction with the vendor.Failing to have the appropriate controls in place may result in vendors who are suspended or debarred receiving federal funds.Prior to contracting with vendors that will be paid with federal funds, the City should follow its established policy and must verify the vendor is not suspended or debarred by checking the SAM exclusions, collecting a certification from the vendor, or adding a clause or condition to the covered transaction with the vendor. Evidence of actions taken to ensure proper suspension and debarment requirements must be maintained by all departments of the City.

Categories

Procurement, Suspension & Debarment Subrecipient Monitoring

Other Findings in this Audit

  • 554793 2024-002
    Material Weakness Repeat
  • 554794 2024-002
    Material Weakness Repeat
  • 554795 2024-002
    Material Weakness Repeat
  • 554796 2024-002
    Material Weakness Repeat
  • 554797 2024-002
    Material Weakness Repeat
  • 554798 2024-002
    Material Weakness Repeat
  • 554799 2024-002
    Material Weakness Repeat
  • 554800 2024-002
    Material Weakness Repeat
  • 554801 2024-002
    Material Weakness Repeat
  • 554802 2024-003
    Material Weakness
  • 554803 2024-003
    Material Weakness
  • 554804 2024-003
    Material Weakness
  • 554805 2024-003
    Material Weakness
  • 554806 2024-001
    Material Weakness Repeat
  • 554807 2024-001
    Material Weakness Repeat
  • 554808 2024-001
    Material Weakness Repeat
  • 554809 2024-001
    Material Weakness Repeat
  • 554810 2024-001
    Material Weakness Repeat
  • 554811 2024-001
    Material Weakness Repeat
  • 554812 2024-001
    Material Weakness Repeat
  • 554813 2024-001
    Material Weakness Repeat
  • 554814 2024-001
    Material Weakness Repeat
  • 1131235 2024-002
    Material Weakness Repeat
  • 1131236 2024-002
    Material Weakness Repeat
  • 1131237 2024-002
    Material Weakness Repeat
  • 1131238 2024-002
    Material Weakness Repeat
  • 1131239 2024-002
    Material Weakness Repeat
  • 1131240 2024-002
    Material Weakness Repeat
  • 1131241 2024-002
    Material Weakness Repeat
  • 1131242 2024-002
    Material Weakness Repeat
  • 1131243 2024-002
    Material Weakness Repeat
  • 1131244 2024-003
    Material Weakness
  • 1131245 2024-003
    Material Weakness
  • 1131246 2024-003
    Material Weakness
  • 1131247 2024-003
    Material Weakness
  • 1131248 2024-001
    Material Weakness Repeat
  • 1131249 2024-001
    Material Weakness Repeat
  • 1131250 2024-001
    Material Weakness Repeat
  • 1131251 2024-001
    Material Weakness Repeat
  • 1131252 2024-001
    Material Weakness Repeat
  • 1131253 2024-001
    Material Weakness Repeat
  • 1131255 2024-001
    Material Weakness Repeat
  • 1131256 2024-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.778 Medical Assistance Program $189.82M
66.458 Capitalization Grants for Clean Water State Revolving Funds $44.91M
21.023 Emergency Rental Assistance Program $26.01M
10.557 Special Supplemental Nutrition Program for Women, Infants, and Children $4.83M
66.468 Capitalization Grants for Drinking Water State Revolving Funds $4.83M
20.205 Highway Planning and Construction $3.85M
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $2.29M
93.044 Special Programs for the Aging_title Iii, Part B_grants for Supportive Services and Senior Centers $2.28M
93.967 Cdc's Collaboration with Academia to Strengthen Public Health $2.26M
93.914 Hiv Emergency Relief Project Grants $2.26M
14.239 Home Investment Partnerships Program $1.78M
93.045 Special Programs for the Aging_title Iii, Part C_nutrition Services $1.47M
16.922 Equitable Sharing Program $1.38M
93.686 Ending the Hiv Epidemic: A Plan for America — Ryan White Hiv/aids Program Parts A and B (b) $1.23M
14.900 Lead-Based Paint Hazard Control in Privately-Owned Housing $1.11M
93.052 National Family Caregiver Support, Title Iii, Part E $998,258
14.241 Housing Opportunities for Persons with Aids $896,847
93.959 Block Grants for Community Mental Health Services $882,312
10.559 Summer Food Service Program for Children $812,224
93.053 Nutrition Services Incentive Program $791,427
14.913 Healthy Homes Production Program $715,871
93.926 Healthy Start Initiative $713,918
14.231 Emergency Solutions Grant Program $656,937
14.218 Community Development Block Grants/entitlement Grants $636,267
21.027 Coronavirus State and Local Fiscal Recovery Funds $503,859
93.069 Public Health Emergency Preparedness $478,826
93.391 Activities to Support State, Tribal, Local and Territorial (stlt) Health Department Response to Public Health Or Healthcare Crises $419,795
66.046 Climate Pollution Reduction Grants $415,749
10.727 Inflation Reduction Act Urban and Community Forestry Program $393,930
16.742 Paul Coverdell Forensic Sciences Improvement Grant Program $350,000
93.958 Block Grants for Community Mental Health Services $292,537
16.838 Comprehensive Opioid Abuse Site-Based Program $261,924
93.243 Substance Abuse and Mental Health Services_projects of Regional and National Significance $225,125
93.940 Hiv Prevention Activities_health Department Based $212,064
20.939 Safe Streets and Roads for All $209,869
93.977 Preventive Health Services_sexually Transmitted Diseases Control Grants $203,928
87.002 Virginia Graeme Baker Pool and Spa Safety $196,404
16.590 Grants to Encourage Arrest Policies and Enforcement of Protection Orders Program $194,285
16.585 Drug Court Discretionary Grant Program $192,717
93.788 Opioid Str $181,997
21.016 Equitable Sharing $178,444
16.741 Dna Backlog Reduction Program $169,982
16.745 Criminal and Juvenile Justice and Mental Health Collaboration Program $135,468
16.575 Crime Victim Assistance $122,381
16.588 Violence Against Women Formula Grants $109,791
93.137 Community Programs to Improve Minority Health Grant Program $108,304
14.228 Community Development Block Grants/state's Program and Non-Entitlement Grants in Hawaii $106,052
93.217 Family Planning_services $99,999
93.071 Medicare Enrollment Assistance Program $90,472
93.043 Special Programs for the Aging_title Iii, Part D_disease Prevention and Health Promotion Services $87,001
93.991 Preventive Health and Health Services Block Grant $83,589
93.421 Strengthening Public Health Systems and Services Through National Partnerships to Improve and Protect the Nation’s Health $69,999
93.994 Maternal and Child Health Services Block Grant to the States $65,369
20.600 State and Community Highway Safety $60,348
93.041 Special Programs for the Aging_title Vii, Chapter 3_programs for Prevention of Elder Abuse, Neglect, and Exploitation $50,956
97.012 Boating Safety Financial Assistance $43,022
93.568 Low-Income Home Energy Assistance $41,650
93.136 Injury Prevention and Control Research and State and Community Based Programs $40,000
20.608 Minimum Penalties for Repeat Offenders for Driving While Intoxicated $37,733
10.576 Senior Farmers Market Nutrition Program $35,394
16.710 Public Safety Partnership and Community Policing Grants $31,413
97.091 Homeland Security Biowatch Program $28,357
93.516 Affordable Care Act (aca) Public Health Training Centers Program $23,216
93.354 Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response $22,405
93.558 Temporary Assistance for Needy Families $22,190
16.738 Edward Byrne Memorial Justice Assistance Grant Program $20,000
93.088 Advancing System Improvements for Key Issues in Women's Health $18,410
93.279 Drug Abuse and Addiction Research Programs $15,332
16.034 Coronavirus Emergency Supplemental Funding Program $8,177
93.889 National Bioterrorism Hospital Preparedness Program $6,200
93.268 Immunization Cooperative Agreements $3,435
93.074 Hospital Preparedness Program (hpp) and Public Health Emergency Preparedness (phep) Aligned Cooperative Agreements $1,500
20.616 National Priority Safety Programs $1,300