Finding Text
CRITERIA: Nonfederal entities are prohibited from contracting with or making subawards to parties that are suspended or debarred. This includes contracts for goods awarded under a nonprocurement transaction expected to equal or exceed $25,000. CONDITION: The City did not check excluded parties list or seek other confirmation to confirm vendors expected to equal or exceed $25,000 were not suspended or debarred. CAUSE: Management did not carefully review the grant policy for compliance requirements, including changes in accounting processes and procedures. EFFECT: The City could pay a vendor with federal funds who is not eligible for reimbursements with federal funds and be required to return grant funds. RECOMMENDATION: The City should carefully review the new policies and procedures related to purchasing and consider making a checklist or implementing additional workflows in the accounting system to ensure compliance. RESPONSE: The practice of checking the debarment list had occurred in the past; the keeping of a "proof of practice" was not done. Going forward, this practice will be documented.