Finding 1167560 (2025-002)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2025
Accepted
2026-01-02
Audit: 378659
Organization: CITY OF DOUGLAS (WY)

AI Summary

  • Core Issue: The City failed to check if contractors were suspended or debarred before awarding contracts, violating federal procurement rules.
  • Impacted Requirements: This noncompliance with 2 CFR 200.214 raises risks of ineligible costs and unfair contract awards.
  • Recommended Follow-Up: Strengthen procurement procedures by ensuring checks are performed and documented, and provide staff training on federal standards.

Finding Text

2025: Procurement Procedures (Significant Deficiency and Noncompliance) Federal Program: American Recovery Plan Act Federal ALN: 21.027 Criteria: Under 2 CFR 200.214 (previously 200.213) requires the City to verify that contractors are not suspended or debarred from doing business with the federal government. This verification may be accomplished by checking the System for Award Management (SAM.gov) or obtaining a certification from the vendor. Condition and Context: During our testing, we identified two (2) transactions for which suspension and debarment checks were not performed or documented prior to contract award. Cause: Undetermined. Effect or Potential Effect: Failure to perform suspension/debarment checks increases the risk of noncompliance with federal regulations, potential ineligible costs changed to federal programs, and diminished assurance that contracts are awards fairly and to responsible parties. Questioned Costs: None. Identification as a Repeat Finding: No. Recommendation: We recommend that management strengthen procurement procedures to ensure compliance with Uniform Guidance requirements. Specifically: - Perform and document suspension and debarment checks (e.g., through SAM.gov) prior to awarding contracts; and - Provide staff training on federal procurement standards and maintain documentation supporting compliance for each federally funded procurement. Responsible Official's Response: Please see the last page of this report for the response to this finding.

Corrective Action Plan

We have reviewed the findings and recommendations in the audit for Fiscal Year 2025. The following are our planned corrective actions for the identified issues: Finding 2025-002: Procurement Procedures. - Change in procedure for Treasurer review of contract awards when presenting to Council to include checking vendor for suspension or debarment and document. - Update pruchasing policies and procedures to add requirement to check for vendor suspension or debarment prior to contract award. We appreciate the constructive feedback provided by your firm which provides us with the opportunity to improve and grow.

Categories

Procurement, Suspension & Debarment

Programs in Audit

ALN Program Name Expenditures
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $1.57M
16.710 PUBLIC SAFETY PARTNERSHIP AND COMMUNITY POLICING GRANTS $116,492
16.039 RURAL VIOLENT CRIME INITIATIVE $25,141
20.205 HIGHWAY PLANNING AND CONSTRUCTION $17,378
20.600 STATE AND COMMUNITY HIGHWAY SAFETY $5,880
20.939 SAFE STREETS AND ROADS FOR ALL $4,289
16.540 JUVENILE JUSTICE AND DELINQUENCY PREVENTION $2,990