Finding Text
Finding 2024-003: U.S. Department of the Treasury
Federal Financial Assistance Listing 21.027
COVID-19 Coronavirus State and Local Fiscal Recovery Funds
Compliance Requirement: Procurement Suspension and Debarment
Type of Finding: Significant Deficiency in Internal Controls over Compliance
Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain
effective internal control over the federal award that provides assurance that
the entity is managing the federal award in compliance with federal statutes,
regulations, and conditions of the federal award.
Per 31 CFR 19.300, prior to enter in subawards and contracts with award funds,
recipients must verify that such contractors and subrecipients are not
suspended, debarred, or otherwise excluded pursuant to 31 CFR § 19.300.
Condition: The County did not retain documentation of verifying that 6 vendors were not
suspended, debarred, or otherwise excluded prior to entering into a transaction
with them.
Cause: The County performed the verification, but did not retain documentation and
we were unable to verify that it was performed prior to the transaction.
Effect: Vendors could be suspended, debarred, or otherwise excluded, and the county
would not be aware.
Questioned Costs: None
Context / Sampling: We tested 32 of 158 transactions subject to suspension and debarment in the
SLFRF program.
Repeat Finding from Prior Year: Yes, prior year finding 2023-003
Recommendation: The County should retain documentation of the review of all vendors.
Views of Responsible Officials: Management agrees with the noted finding. Refer to Corrective Action Plan.