Finding Text
2024-001: Internal Controls over Compliance for Procurement Suspension & Debarment
U.S. DEPARTMENT OF TREASURY
COVID-19 Coronavirus State and Local Fiscal Recovery Funds – ALN 21.027
Criteria: Per 2 CFR sections 200.318 through 200.327, [entities] must use their own documented
procurement procedures, which reflect applicable state and local laws and regulations, provided
that the procurements conform to applicable federal statutes and the procurement requirements
identified in 2 CFR Part 200. Further, when a non-federal entity enters into a covered transaction
with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2
CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise
excluded from participating in the transaction.
Condition: The City did not follow its Grant Standard Operating procedures for validating that a
contractor was not suspended or debarred or otherwise excluded from participating in the
transaction.
Cause: The contract agreement was finalized without validation that all proper procurement
procedures had been followed.
Effect: By not following the City’s procedures in place, it puts the City at risk of doing business
with companies who are suspended, debarred or otherwise excluded from doing business with
the federal government.
Questioned Costs: $0
Context: The auditor tested one procurement transaction entered into during 2024 using COVID-
19 Coronavirus State and Local Fiscal Recovery Funds. The City’s Grant Standard Operating
procedures over suspension and debarment were not followed for this one procurement.
Identification of Repeat Finding: Not a repeat finding.
Recommendation: We recommend the City perform a separate individual check of contract files
to ensure the City’s Grant Standard Operating procedures are followed and documented prior to
entering into a contract agreement with covered contractors.
Views of Responsible Officials and Planned Corrective Actions: Management agrees with this
finding and is in the process of developing internal controls to ensure timely and appropriate
actions are taken on the deficiency noted. Additional details can be found in the City of
Bloomington’s Corrective Action Plan.