Finding 1148158 (2024-002)

2024 – 002: Suspension and Debarment: Federal Agency: U.S. Department of Treasury, Federal Program Name: COVID-19 State and Local Fiscal Recovery Funds, Assistance Listing Number: 21.027, Federal Award Identification Number and Year: SLRFP0410 – 2024, Award Period: January 1, 2024 – December 31, 2024, Type of Finding: Significant Deficiency in Internal Control over Compliance; Other Matter Criteria or specific requirement: 2 CFR § 180.300 requires that before the County enters into a covered transaction with an entity at a lower tier, the County 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. 2 CFR 200.303 requires that the entity have sufficient controls over compliance related to federal awards. Condition: During our testing, we noted an instance where there was no documentation of this verification being performed. Questioned costs: None Context: During our testing, it was noted that one of six contracts that were tested were entered into without the County verifying and retaining documentation of said verification that the vendor was not suspended or debarred by the federal government. Cause: The County was unaware this type of contract met the criteria applicable for suspension and debarment. Effect: The auditor noted no instances of noncompliance with the provisions of procurement, suspension, and debarment; however, the lack of internal controls over these compliance requirements provides an opportunity for noncompliance. Repeat Finding: No. Recommendation: We recommend the County ensure that this suspension and debarment verification occurs before entering covered transactions and that supporting documentation of this internal control is retained. Views of responsible officials: Management does not disagree with the finding.