Finding 1145290 (2024-007)

Significant Deficiency
Requirement
I
Questioned Costs
-
Year
2024
Accepted
2025-06-30
Audit: 360575
Organization: County of Berrien (MI)

AI Summary

  • Core Issue: The County failed to verify that three out of four vendors were not suspended or debarred when engaged for contracts over $25,000.
  • Impacted Requirements: This noncompliance violates 2 CFR Part 180, which mandates checks against the list of excluded parties for federal procurement and nonprocurement contracts.
  • Recommended Follow-up: The County should update and enforce its policies and procedures for grant compliance to ensure proper vendor checks are consistently conducted.

Finding Text

2024-007 – Suspension and Debarment Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance (Suspension and Debarment). Federal program(s) U.S. Department of Treasury -  COVID-19 - Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) (ALN 21.027); Direct award, and Passed through Michigan State Housing Development Authority and Michigan Department of Natural Resources; 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. For three of the four vendors selected for testing, the County was unable to provide evidence that the vendors were not suspended, debarred, or otherwise excluded at the time they were engaged to provide goods or services. Cause. The County 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. As a result of this condition, the County was exposed to an increased risk that disbursements of federal awards could be made to vendors or subrecipients suspended or debarred by the federal government. 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 County review its written policies and procedures over federal awards with employees responsible for grant compliance to ensure that they are being followed consistently. View of Responsible Officials. Vendors are reviewed based on specific criteria upon addition to the accounts payable system for the County. This review process includes review for suspension, debarment, and excluded parties. The County will review grant compliance requirements with employees responsible for federal awards and request retention of documents verifying compliance. Responsible Official. County Administrator/Controller Estimated Completion Date. December 31, 2025

Categories

Procurement, Suspension & Debarment Allowable Costs / Cost Principles

Other Findings in this Audit

  • 568845 2024-005
    Significant Deficiency
  • 568846 2024-007
    Significant Deficiency
  • 568847 2024-006
    Significant Deficiency
  • 568848 2024-007
    Significant Deficiency
  • 568849 2024-006
    Significant Deficiency
  • 568850 2024-007
    Significant Deficiency
  • 568851 2024-006
    Significant Deficiency
  • 1145287 2024-005
    Significant Deficiency
  • 1145288 2024-007
    Significant Deficiency
  • 1145289 2024-006
    Significant Deficiency
  • 1145291 2024-006
    Significant Deficiency
  • 1145292 2024-007
    Significant Deficiency
  • 1145293 2024-006
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
21.027 Coronavirus State and Local Fiscal Recovery Funds $994,845
93.268 Immunization Cooperative Agreements $150,870
93.959 Block Grants for Prevention and Treatment of Substance Abuse $79,014
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $73,054
20.703 Interagency Hazardous Materials Public Sector Training and Planning Grants $71,515
93.994 Maternal and Child Health Services Block Grant to the States $43,521
20.509 Formula Grants for Rural Areas and Tribal Transit Program $43,372
93.069 Public Health Emergency Preparedness $39,023
93.354 Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response $31,891
93.778 Medical Assistance Program $29,902
93.658 Foster Care Title IV-E $18,596
66.472 Beach Monitoring and Notification Program Implementation Grants $17,000
10.557 Wic Special Supplemental Nutrition Program for Women, Infants, and Children $14,351
93.991 Preventive Health and Health Services Block Grant $14,250
93.870 Maternal, Infant and Early Childhood Home Visiting Grant $12,788
93.092 Affordable Care Act (aca) Personal Responsibility Education Program $9,474
93.217 Family Planning Services $7,966
93.788 Opioid Str $6,031
93.116 Project Grants and Cooperative Agreements for Tuberculosis Control Programs $5,070
97.042 Emergency Management Performance Grants $4,907
20.600 State and Community Highway Safety $3,365
10.553 School Breakfast Program $2,925
10.555 National School Lunch Program $1,262
93.563 Child Support Services $396
93.940 Hiv Prevention Activities Health Department Based $242
16.540 Juvenile Justice and Delinquency Prevention $78