Finding Text
Federal Agency: U.S. Department of the Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: Unknown Award Period: March 3, 2021 – December 31, 2026 Type of Finding: Significant Deficiency in Internal Control over Compliance Compliance Requirement: Procurement, Suspension & Debarment Criteria: 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 non-procurement 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 City entered into procurement transactions that exceeded the covered threshold and while the city did perform a review of suspension and debarment status, it did not document that the review was completed prior to approving the procurement transaction in accordance with 2 CFR section 180.220. Questioned Costs: None Context: The City did not document the date of the suspension and debarment review for two transactions that exceeded the covered threshold. Cause: The City did not have procedures in place to help ensure that the date of review was documented. Effect: Certain vendors could be used that are considered suspended or debarred by the federal government resulting in noncompliance. Repeat Finding: No Recommendation: We recommend the City revise its policies and procedures to ensure that documentation as to the date of the review of suspension and debarment status is maintained with the procurement history of each transaction that requires such a search. Views of Responsible Officials: There is no disagreement with the finding.