Core Issue: The Town failed to verify suspension and debarment compliance for four transactions, risking contracts with ineligible vendors.
Impacted Requirements: Non-federal entities must ensure compliance with 2 CFR section 200.214, which prohibits contracting with suspended or debarred parties.
Recommended Follow-Up: Implement procedures to document checks on all contractors to confirm they are not suspended or debarred.
Finding Text
2024-002 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 Other Matter 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 four covered transactions. Cause: Lack of appropriate oversight resulted in required suspension and debarment checks not being performed. Effect: Grant transactions are not supported adequately, and 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 four 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.
Corrective Action Plan
Condition: Suspension and debarment compliance was not verified for four covered transactions. Corrective Action Planned: The Town will implement procedures to include a suspension and debarment certification in all federal contracts that are considered covered transactions to ensure that the contractors are eligible to receive federal funds and not excluded or disqualified from doing business. Anticipated Completion Date: March 31, 2026 Contact: Bryan Sawyer, Town Administrator
Categories
Procurement, Suspension & DebarmentInternal Control / Segregation of DutiesSubrecipient MonitoringSignificant Deficiency