Finding Text
Federal Program: U.S. Department of Treasury passed through Ste. Genevieve County, Missouri: Coronavirus State and Local Fiscal Recovery Funds (21.027). Criteria: According to 2 CFR 180.220, when a sub-recipient of federal awards uses federal money to acquire goods and services expected to cost more than $25,000, the sub-recipient must determine if the vendor is suspended, debarred, or otherwise excluded from doing business with the federal government. Condition: The District purchased goods from two vendors totaling greater than $25,000 that required the District to determine the vendors' status with the federal government. The vendors were, in fact, not excluded parties, and the District made the determination using SAM.gov before the disbursements were made. However, the District did not keep supporting documentation that the determination was made. The District kept supporting documentation that the determination was made for one vendor paid $854,178 of grant funds. However, the District did not keep supporting documentation that the determination was made for one vendor paid $120,152 of grant funds. Cause: The District was unaware that they needed to keep documentation of checking the vendor's status on System for Award Management (SAM). Effect: The District did comply with the federal compliance requirements, however, internal controls were such that noncompliance could occur and go undetected. Questioned Costs: None. Context: Actual expenditures of the program were $974,330 during the fiscal year ended December 31, 2024. Repeat Finding: No. Recommendation: We recommend the District verify a vendor's status by checking the System for Award Management (SAM) maintained by the General Services Administration before making purchases expected to exceed $25,000 and to keep supporting documentation of the verification of the vendor's status. Views of Responsible Officials: The District will verify all vendors' status using the System for Award Management (SAM) maintained by the General Services Administration before making purchases expected to exceed $25,000 and keep all supporting documentation.