Finding Text
Federal Agency: U.S. Department of Treasury
Federal Program Title: Coronavirus State and Local Fiscal Recovery Funds
Federal Assistance Listing Number: 21.027
Federal Award Identification Number and Year: N/A / SLFRP1191-2021
Pass-Through Agency: City of Duluth / St. Louis County
Pass-Through Number(s): N/A
Award Period: 7/7/2023 - 10 years from date certificate of completion is issued / 5/19/2021 - 12/31/2026
Type of Finding:
Material Weakness in Internal Control over Compliance and Other Matters
Criteria or Specific Requirement: 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. This verification may be accomplished by
(1) checking the System for Award Management (SAM) Exclusions maintained by the General
Services Administration (GSA) and available at https://www.sam.gov/portal/public/SAM/
(2) collecting a certification from the entity, or
(3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300).
Condition: During our testing we noted the Organization did not apply its suspension and debarment
procedures for one contractor sampled as they did not perform nor retain adequate documentation in
accordance with Uniform Guidance.
Questioned Costs: N/A
Context: Three out of three selections did not have any suspension/debarment procedures followed
until after entering into the covered transaction.
Cause: Management was aware of the suspension and debarment requirements dictated by the
Uniform Guidance, however, did not follow their policy for either checking sam.gov or receiving a selfcertification
from the contractor.
Effect: Potential for the Organization to do business with entities that are suspended or debarred which
is not allowed per Uniform Guidance.
Repeat Finding: This is a repeat finding – see finding 2023-001.
Recommendation: The Organization should ensure they follow their suspension and debarment
policy. The Organization should ensure documents are retained to support whether suspension and
debarment policies were followed for contractors in years past.
Views of responsible officials and planned corrective actions: There are no disagreements with
the audit finding. The Organization will ensure they follow their suspension and debarment policy
moving forward and documentation is retained.