Finding Text
Federal Agency: U.S. Department of Transportation Federal Program Name: Highway Planning and Construction Assistance Listing Number: 20.205 Federal Award Identification Number and Year: STP-5419 (613) - 2021 Pass-Through Agency: Missouri Department of Transportation Pass-Through Number(s): STP-5419 (613) Award Period: 2025 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Per Uniform Guidance 2 CFR 180.300 nonfederal entities entering into covered transactions must verify the party is not suspended or debarred from conducting business by the federal government. This can be performed by: Checking SAM exclusions, collecting a certification from the party, or adding a clause or condition to the covered transaction. Condition: The City did not maintain documentation indicating the date the SAM check was completed prior to entering into a covered transaction. Questioned costs: None Context: No process exists to review SAM exclusions list comparing the listing of vendors with expenditures exceeding $25,000 and documenting date this check was performed. Cause: The City does not have a control in place to ensure the SAM exclusion check is performed before entering into a covered transaction. Effect: The City could enter into a covered transaction with an entity that is suspended or disbarred. Repeat Finding: No Recommendation: We recommend that the City evaluate its procedures and implement an additional control to ensure verifications checks are occurring prior to entering into contracts with a vendor. Views of responsible officials: There is no disagreement the audit finding.