Finding Text
2024-014 Noncompliance with Suspension and Debarment Requirements Grantor Environmental Protection Agency – Assistance Listing 66.458 Clear Water State Revolving Fund Passed through Louisiana Department of Environmental Quality – Number CS-221732.01 Grant Period – Year ended June 30, 2024 First reported 2024 Type Material Weakness, Noncompliance Condition The Town failed to establish a policy to outline procedures to be completed to identify contractors that are suspended or debarred. Additionally, the construction contract did not include a compliance clause in the contract, the Town did not obtain certifications from contractors regarding their suspension or debarment status, nor did it document searches conducted in the System for Award Management (SAM) Exclusions to verify contractor eligibility. We did search the list and did not find the contractor. Criteria According to the Uniform Guidance, nonfederal entities must verify that contractors are not suspended, debarred, or otherwise excluded from participating in federal programs. This can be achieved by checking the SAM Exclusions, obtaining a certification from the contractor, or including a compliance clause in the contract. Furthermore, entities must document the verification process. Cause The Town did not have adequate procedures in place to ensure compliance with federal suspension and debarment requirements. Effect The lack of proper verification and documentation could result in the Town engaging with ineligible contractors, potentially leading to noncompliance with federal regulations and jeopardizing federal funding. Questioned Costs None Recommendation It is recommended that the Town develop and implement a policy to verify the suspension and debarment status of contractors. This policy should include procedures for checking the SAM Exclusions, obtaining necessary certifications, and documenting the verification process. Additionally, training should be provided to staff responsible for procurement to ensure understanding and compliance with these requirements. Management Response See management’s corrective action plan.