Finding 1148170 (2024-001)

Federal Agency: U.S. Department of Treasury Federal Program Name: COVID-19 Coronavirus State and Local Fiscal Recovery Effort Assistance Listing Number: 21.027 Award Period: March 2020 – December 2026 Pass-through Entity: N/A – direct award Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: Some federal programs are subject to suspension and debarment requirements, which are designed to ensure that federal funds are not awarded to individuals or entities that have a history of noncompliance with federal regulations or that pose a risk to the integrity of federal programs. The suspension and debarment regulations require recipients of federal funding to ensure contractors and subrecipients are not suspended or debarred by the federal government prior to executing a contract. Condition: The County did not have a process implemented to perform suspension and debarment assessments for new contracts funded by federal awards. In 2025, the County performed a suspension and debarment assessment for the eight contracts tested that were applicable to the suspension and debarment requirements funded by federal monies. Going forward, the County will perform suspension and debarment assessments for all new contracts. Questioned Costs: None Context: Procurement was direct and material to the Coronavirus State and Local Fiscal Recovery Effort. Suspension and debarment assessments were performed but after the contract was awarded. As a result, the suspension and debarment assessments were performed late. Cause: Prior to 2025, the County did not have a process to perform suspension and debarment assessments outlined in 2 CFR sections 416.1(a), 416.1(b) and 417.215(a)(1) and in 7 CFR section 210.21(g), 215.14a(e), 220.16(f), and 225.17(e). Effect: Federal funding could be spent on organizations that are suspended or disbarred. Recommendation: The County should ensure that suspension and debarments checks are performed on contracts above $25,000 that are funded through federal awards. Repeat Finding: No Views of Responsible Officials: There is no disagreement with the audit finding.