Finding Text
2024-003 - Suspension and Debarment - Verification
Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance (Suspension and Debarment).
Federal program(s)
U.S. Department of Homeland Security -
Assistance to Firefighters Grant (ALN 97.044); Direct award; All project numbers.
Criteria. Under the requirements of 2 CFR Part 180, for covered transactions for procurement and nonprocurement contracts that are expected to equal or exceed $25,000, the grantee must verify that the party being awarded a procurement and nonprocurement contract is not suspended, debarred, or otherwise excluded by checking the list of excluded parties, obtaining certification from the vendor or subrecipient, or including a clause or condition to the covered transaction with that entity.
Condition. The Township was unable to provide evidence that one of the vendors selected for testing was not suspended, debarred, or otherwise excluded at the time the Township hired the vendor to provide goods or services.
Cause. The Township does not have the proper internal controls in place to ensure that the appropriate procedures are being followed for covered transactions in accordance with the requirements of the Uniform Guidance.
Effect. While none of the vendors tested appeared to be suspended or debarred, documentation does not exist to support that the Township verified its vendors paid with federal dollars were not suspended or debarred prior to contracting with them.
Questioned Costs. No costs have been questioned as a result of this finding inasmuch as no unallowable costs were identified.
Recommendation. We recommend that the Township review its written policies and procedures over federal awards to ensure that the appropriate suspension and debarment evidence of verifications are retained for all vendors providing goods or services in excess of $25,000.
View of Responsible Officials. We acknowledge the finding of immaterial noncompliance and the identified significant deficiency in our internal controls related to compliance with suspension and debarment requirements. We take this matter seriously and are committed to strengthening our compliance processes. Relevant personnel will undergo updated training on suspension and debarment procedures, including use of the SAM.gov exclusion database.
Responsible Officials. Finance Director
Estimated Completion Date. December 31, 2025