Finding 1149637 (2024-001)

Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Federal Agency: U.S. Department of the Treasury Federal Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), ALN No. 21.027 Compliance Requirement: Suspension and Debarment Repeat Finding: No Condition: During our testing of five covered transactions (three vendors and two subrecipients), we noted that management was not able to provide supporting documentation that suspension and debarment procedures were performed before the start of the procurement activity. Questioned Costs: None Context: For two of the three vendors tested for suspension and debarment, management was not able to provide the required supporting documentation and for one of the three vendors tested, the contract agreement was signed before the suspension and debarment verification was completed. Criteria: 2 CFR 180.300 prohibits entities from contracting under covered transactions to parties that are suspended or debarred from doing business with the federal government. A contract for goods or services is a covered transaction if awarded as a grant or payment for specified use and if the amount of the contract is expected to equal or exceed $25,000. In order to comply with federal suspension and debarment requirements, the City can perform a search in the federal System of Award Management (SAM) website, which tracks the entities that the federal government has determined are ineligible to receive federal funding; collect a certification from the entity; or add a clause or condition to the contract. Cause: There was significant turnover within the finance department of the City and grants administration was missing supervision by key personnel. Effect: The finding indicates that there could be some process improvements in how contracts are reviewed, documented and maintained to provide evidence the compliance requirements are being met. Recommendation: We understand the grants administration has been assigned to a specific department. We recommend that the City either obtain certifications from vendors stating their organization is not suspended, debarred, or otherwise excluded from participation in federal assistance programs or document the procedures performed to verify the vendor is not identified as suspended or debarred on the SAM website. We recommend that the City implement proper procedures to ensure that all contractual documentation is maintained and able to be located.