Finding Text
Federal Agency: U.S. Department of the Interior Federal Program Title: Central Valley Project Improvement Act Assistance Listing Number: 15.648 Federal Award Identification Number and Year: F23AP02520-00 Award Period: July 1, 2023 – June 30, 2024 Compliance Requirement Affected: I. Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirements: 2CFR § 200.303 Internal controls require a recipient of federal awards to: (a) Establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: While there was evidence that suspension and debarment verification checks were performed, the City was unable to provide evidence for when the checks were performed to support the fact that they took place prior to the related procurement. Questioned Costs: None noted. Context: The condition was noted on 1 of 1 of the procurement transactions selected for testing. Cause: Procedures were not in place to retain evidence of when debarment status checks took place. Effect: The City is unable to prove that internal control procedures over suspension and debarment compliance were performed in a timely manner. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the City add a section to its standard contractor and subrecipient contracts for the other party to certify they are not suspended or debarred. In addition, we recommend the City establish controls to ensure that evidence of suspension and debarment compliance procedures is retained. Views of Responsible Officials: The City agrees with finding and will implement steps to verify if the contractor has been suspended or debarred from federal contracts.