Finding Text
Criteria: Title 2 U.S. Code of Federal Regulations Part 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control designed to reasonably ensure compliance with federal statutes, regulations, and the terms and conditions of the federal award. Effective internal controls should include procedures in place to ensure the required certifications for covered contracts and subawards are received, documented, and contracts are not made with a debarred or suspended party. Condition: During our testing, it was noted that the County did not have adequate controls designed to ensure that suspension and debarment requirements were being met. Context: Of the 3 vendors tested, we noted that all 3 were not verified by the County or certifications from the vendors were not collected to ensure the vendors were neither suspended or debarred. Cause: The County has not designed and implemented internal controls to ensure compliance with suspension and debarment requirements outlined. Effect: Failure to obtain the required certifications or perform verification procedures with SAM.gov could result in the payment of federal funds to vendors that are suspended or debarred from participation in federal assistance programs. Recommendation: We recommend that the County implement internal controls to ensure that suspension and debarment assessments are performed during the procurement and contracting phase. In addition, sufficient documentation should be retained to evidence suspension and debarment verification is performed. Management's Response: We will implement internal controls to ensure that suspension and debarment assessments are performed during the procurement and contracting phase, and we will retain sufficient documentation to evidence that suspension and debarment verficiation is performed.