Finding 1152534 (2024-001)

Material Weakness
Requirement
I
Questioned Costs
-
Year
2024
Accepted
2025-09-10
Audit: 365997
Organization: City of Columbus (IN)

AI Summary

  • Core Issue: The City lacks effective internal controls to verify that contractors and subrecipients are not suspended or debarred before receiving COVID-19 funds.
  • Impacted Requirements: Compliance with procurement and suspension/debarment regulations is not being met, risking the eligibility of contractors paid with federal funds.
  • Recommended Follow-Up: Establish a robust internal control system with oversight to ensure all contractors receiving $25,000 or more are verified against suspension and debarment lists.

Finding Text

FINDING 2024-001 Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Suspension and Debarment Federal Agency: Department of the Treasury Federal Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listings Number: 21.027 Federal Award Number and Year (or Other Identifying Number): 2024 Compliance Requirement: Procurement and Suspension and Debarment Audit Finding: Material Weakness Condition and Context Prior to entering into subawards and covered transactions with the COVID-19 - State and Local Fiscal Recovery Funds (SLFRF) award funds, recipients are required to verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded. "Covered transactions" include, but are not limited to, contracts for goods and services awarded under a nonprocurement transaction (i.e., grant agreement) that are expected to equal or exceed $25,000. The verification is to be done by checking the Excluded Parties List System (EPLS), collecting a certification from that person, or adding a clause or condition to the covered transaction with that person. An internal control system was not in place at the City to ensure compliance with the Procurement and Suspension and Debarment compliance requirement. A population of nine covered transactions that equaled or exceeded $25,000 paid from SLFRF award funds received from the U.S. Department of the Treasury was identified. Three covered transactions were selected for testing. The City had procedures in place to verify that the persons and entities related to each of the three covered transactions were not suspended, debarred, or otherwise excluded; however, one person was responsible for verifying compliance, without an oversight, review, or approval process in place. The lack of internal controls was a systemic issue throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." Cause The City's procedures to verify vendors' suspension or debarment status were not adequate, as only one employee was involved in this process, with no oversight. City officials were not aware that a second review was necessary for suspension and debarment requirements. Effect Without the proper design or implementation of internal controls, the City cannot ensure that contractors paid with federal funds are eligible to participate in federal programs. Any program funds the City used to pay contractors that have been suspended or debarred would be unallowable, and the funding agency could potentially recover the funds. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the City establish a proper system of internal controls to ensure that the current procedures in place are properly implemented for all persons and entities that are paid $25,000 or more, all or in part with federal funds, to ensure they are not suspended, debarred, or otherwise excluded from participating in federal programs. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

Categories

Procurement, Suspension & Debarment Subrecipient Monitoring Internal Control / Segregation of Duties

Other Findings in this Audit

  • 576092 2024-001
    Material Weakness
  • 576093 2024-002
    Material Weakness
  • 1152535 2024-002
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
20.507 Federal Transit Formula Grants $2.82M
20.106 Airport Improvement Program, Infrastructure Investment and Jobs Act Programs, and Covid-19 Airports Programs $2.09M
21.027 Coronavirus State and Local Fiscal Recovery Funds $450,688
20.205 Highway Planning and Construction $313,165
14.218 Community Development Block Grants/entitlement Grants $180,920
45.024 Promotion of the Arts Grants to Organizations and Individuals $75,000
97.044 Assistance to Firefighters Grant $54,956
20.505 Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research $34,095