Finding Text
Finding No. SA 2024-002 – Suspension and Debarment
Federal Assistance Listing Number: 21.027
Federal Program Title: Coronavirus State and Local Fiscal Recovery Funds
Federal Agency: U.S. Department of Treasury
Award Period: Fiscal year 2024
Criteria or Specific Requirement:
2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement, suspension, and debarment. The City should have internal controls designed to ensure compliance with those provisions.
Condition:
The City was unable to provide evidence that the suspension and debarment status of vendors was checked prior to entering into purchasing contracts.
Cause:
Procedures were not in place to retain evidence of the debarment status check, as the transaction was exempt from the bidding process as per the City’s Purchasing Policy and Procedures.
Effect:
The City is unable to prove that debarment checks took place prior to entering into purchasing Contracts, which may lead to non-compliance with the program requirements.
Questioned Costs:
None.
Repeat finding:
Yes, see Summary Schedule of Prior Year Audit Findings 2023-003
Recommendation:
We recommend that management review its procedures for retaining evidence of debarment status checked prior to entering into purchase agreements.
Views of responsible officials and planned corrective actions:
Per the City’s Purchasing Policy & Procedures page 29, “Subscriptions” are listed as a type of purchase that is purchase order exempt. The City’s AP invoice requirements do not reference or specify the requirement of attaching a Suspension and Debarment report to invoice backup. However, moving forward, the new procurement policy for the City has addressed this by including an excerpt specifically for this issue. The Finance Department continuously encourages the departments and staff to attach a copy of the SAM.GOV report for federally funded invoices, even if no PO is needed.