Finding Text
SD 2024‐002 SUSPENSION AND DEBARMENT
United States Environmental Protection Agency
ALN 66.456 – National Estuary Program
Federal Award ID Number: CE‐00D90119, 4T‐02D39922, CE‐02D56923
2024 Funding
Repeat finding
Criteria: 2 CFR 200.303 requires non‐federal entities to establish and maintain effective internal
controls. Pursuant to 2 CFR section 180.300, the Council may not contract with or make subawards
to parties that are identified as being suspended or debarred by the Federal Government. The Council
must verify the parties’ eligibility to receive payment from a program funded by a Federal grant prior
to entering a covered transaction (as defined in 2 CFR section 180.220).
Condition: The Council did not have a process in place to verify that subrecipients and vendors for
covered transactions were not suspended or debarred.
Cause: Management was not aware of this procurement requirement.
Effect: The Council could inadvertently enter a covered transaction with a suspended or debarred
party, resulting in the disallowance of payments made to that party as eligible costs under the Federal
program.
Questioned Costs: None.
Perspective: Many of the subawards made by the Council were to other local governments or
universities, which are entities unlikely to be suspended or debarred. As part of our compliance
testing, we tested a sample of subrecipients and vendors for suspension and debarment, noting no
exceptions.
Recommendation: We recommend the Council continue with the controls that were implemented
in late 2024 to ensure the Council does not enter a subaward or other covered transaction with a
party that is suspended, debarred or otherwise excluded from participating in federal awards. As the
control was not in place for the majority of 2024, it is a repeat finding.
Management Response: The IRL Council amended its Operating Procedures following the FY 2023
finding to include suspension and debarment procedures into procurement methods for activities
that are federally funded. The IRL Council Chief Operating Officer, immediately checked all current
vendors for compliance within SAM.gov and all new or amended agreements have since been
checked in SAM.gov for compliance. As noted by Carr, Riggs, and Ingram there were no instances of
exception in their testing. Due to the timing of the FY 2023 finding, FY 2024 would also be considered
a finding regardless of any corrective action taken.