Finding 1151273 (2024-002)

2024-002 Suspension & Debarment Federal Agency: U.S. Department of Treasury Federal Program Names: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Numbers: 21.027 Federal Award Identification Number and Year: SLFRP0756; 2020 Award Periods: March 1, 2020 – December 31, 2024 Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria or Specific Requirement: 2 CFR 200 states that nonfederal 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 nonprocurement 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). Condition: The County does not have established procedures to meet the compliance requirement for suspension & debarment. Questioned Costs: None. Context: While performing compliance procedures, it was noted that the County does not have established policies regarding suspension and debarment and procedures to verify were not completed. Subsequent client procedures concluded that none of the contractors or vendors were suspended or debarred. Cause: The County’s current procurement policy does not include a clause about suspension and debarment verification to establish procedures. 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. Repeat Finding: Yes; 2023-003 Recommendation: We recommend the County review and update procurement policies for the entire County to include suspension and debarment to ensure it meets the minimum requirements of 2 CFR 200 for all federal grants. View of Responsible Officials: There is no disagreement with the finding.