Finding 1156999 (2024-004)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2024
Accepted
2025-09-30
Audit: 369308
Organization: Town of Clinton (MA)

AI Summary

  • Core Issue: The Town failed to verify suspension and debarment compliance for five vendors, risking contracts with ineligible parties.
  • Impacted Requirements: Compliance with 2 CFR section 200.214, which prohibits contracting with suspended or debarred entities.
  • Recommended Follow-Up: Implement formal procedures to ensure all contractors are checked for suspension or debarment status before awarding contracts.

Finding Text

2024-004 U.S. Department of the Treasury COVID-19 – Coronavirus State and Local Fiscal Recovery Funds - ALN 21.027 Significant Deficiency in Internal Controls Over Compliance and Compliance Finding Criteria: Per 2 CFR section 200.214, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Condition: Suspension and debarment compliance was not verified for five vendors. Cause: Lack of formal federal procurement policies and procedures and resulted in required suspension and debarment checks not being performed. Effect: The Town is at risk of awarding contracts to vendors not eligible to participate in federal awards programs. It was determined that none of the five vendors were suspended or debarred from federal awards. Questioned Costs: None Repeat Finding from Prior Year: No Recommendation: The Town should implement procedures to document that all contractors under covered transactions that are performing services for the grant are not suspended or debarred. Views of Responsible Official: Management agrees with the finding.

Corrective Action Plan

Finding 2024-004 – Suspension and debarment compliance was not verified for five vendors. Corrective Action Planned: The Town of Clinton has verified that vendors listed in the period ending March 31, 2024 expenditure report were not on the Federal suspension or debarment list. The Town will review all applicable vendors for suspension and debarment compliance in the future. Completion Date: September 29, 2025 Contact: Michael J. Ward, Town Administrator

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 1156989 2024-001
    Material Weakness Repeat
  • 1156990 2024-001
    Material Weakness Repeat
  • 1156991 2024-001
    Material Weakness Repeat
  • 1156992 2024-001
    Material Weakness Repeat
  • 1156993 2024-002
    Material Weakness Repeat
  • 1156994 2024-002
    Material Weakness Repeat
  • 1156995 2024-002
    Material Weakness Repeat
  • 1156996 2024-002
    Material Weakness Repeat
  • 1156997 2024-002
    Material Weakness Repeat
  • 1156998 2024-003
    Material Weakness Repeat
  • 1157000 2024-005
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
21.027 Coronavirus State and Local Fiscal Recovery Funds $880,295
10.553 School Breakfast Program $207,723
84.010 Title I Grants to Local Educational Agencies $153,905
66.468 Drinking Water State Revolving Fund $82,699
10.555 National School Lunch Program $76,986
10.559 Summer Food Service Program for Children $60,022
84.002 Adult Education - Basic Grants to States $40,000
16.738 Edward Byrne Memorial Justice Assistance Grant Program $39,204
84.367 Supporting Effective Instruction State Grants (formerly Improving Teacher Quality State Grants) $21,435
84.424 Student Support and Academic Enrichment Program $21,340
84.027 Special Education Grants to States $18,959
84.425 Education Stabilization Fund $8,927
84.365 English Language Acquisition State Grants $5,446
84.048 Career and Technical Education -- Basic Grants to States $3,200
84.173 Special Education Preschool Grants $1,167