Finding 1150288 (2024-002)

2024-002 Suspension and Debarment Type of Finding Significant Deficiency in Internal Control Over Compliance Compliance Requirement Procurement, Suspension and Debarment Criteria or Specific Requirement 2 CFR 200 states that non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220). All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity 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. Condition The County did not retain documentation of suspension/debarment verification. Additionally, the current policy in place does not meet Uniform Guidance (UG) requirements. Questioned Costs None Context During testing, it was noted that the County did not retain supporting documentation showing evidence of a search for suspension and debarment. Furthermore, the County does have a purchasing policy but not a procurement policy that follows Uniform Guidance (UG) nor does the County have a consistent county-wide policy. Cause The County does have a purchasing policy but not a procurement policy that follows Uniform Guidance (UG) nor does the County have a consistent county-wide policy. Repeat Finding Not a repeat finding Effect The County is not in compliance with suspension and debarment requirements. Vendors may be paid with federal funds that are suspended and debarred entities which would not be in compliance with the Uniform Guidance. Recommendation We recommend the County review and update procurement policies for the entire County to ensure it meets the minimum requirements of 2 CFR 200 for all federal grants and establish a procurement process in order to ensure this policy is followed which includes adding language over suspension & debarment. Views of Responsible Officials There is no disagreement with the finding.