Finding 1153777 (2024-001)

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: Unknown Award Period: March 3, 2021-December 31, 2025 Type of Finding: Other Matters and Significant Deficiency in Internal Control Over Compliance Compliance Requirement: Procurement, Suspension, and Debarment Criteria or Specific Requirement: 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 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 entered into a procurement transaction that exceeded the covered transaction threshold and did not perform a search for suspension and debarment nor did it receive a certification from the entity or include a clause regarding suspension and debarment status in the contract with the entity in accordance with 2 CFR section 180.220. Questioned Costs: None Context: Supporting documentation of the search for suspension and debarment was requested for the one procurement transaction that exceeded the covered transaction threshold in 2024. No deviations were expected. The county had no support or documentation for a suspension and debarment status for this transaction. Cause: The County did not have a procedure in place to perform a search for suspension and debarment prior to awarding contracts or request a certification from the entity or include a clause regarding suspension and debarment status in the contract with the entity when the contract was not a Health and Human Services procurement transaction. Effect: The potential exists that the county could award contracts to vendors who are suspended or debarred by the federal government resulting in noncompliance. Repeat Finding: No. Recommendation: We recommend that the County review and update policies and procedures to help ensure that all federal grants with covered transactions have vendors reviewed for suspension and debarment status prior to entering into the transaction and that documentation of the status is maintained with the procurement history of each transaction that it is required for. View of Responsible Officials: There is no disagreement with the audit finding.