Finding Text
2025-001 – Procurement, Suspension, and Debarment Finding Type. Immaterial Noncompliance (Procurement, Suspension, and Debarment) Program. Coronavirus State and Local Fiscal Recovery Funds (CSLFRF); U.S. Department of Treasury; ALN 21.027; Award SLFRP0127. Criteria. Recipients of federal awards are required to follow their own internal purchasing policies, as well as comply with purchasing standards set forth in the Uniform Guidance. Under the requirements of 2 CFR Part 180 covered transactions for procurement and nonprocurement contracts that are expected to equal or exceed $25,000, the grantee must verify that the party being awarded a procurement and nonprocurement contract is not suspended, debarred, or otherwise excluded by checking the list of excluded parties, obtaining certification from the vendor or subrecipient, or including a clause or condition to the covered transaction with that entity. Condition. The City did not complete a check for suspension and debarment for one out of three vendors selected for testing during the year. The City could not provide evidence that the selected vendor was not suspended, debarred, or otherwise excluded at the time the City entered into the covered transactions. Cause. Management has indicated that the City has a procurement policy in place that includes verifying compliance with suspension and debarment rules, however, the City did not follow the appropriate procedures in compliance with federal requirements in this instance. Effect. As a result of this condition, the City did not fully comply with the requirements of the Uniform Guidance and is exposed to an increased risk that future noncompliance could occur and not be prevented or detected by the City's internal controls. Questioned Costs. No costs were required to be questioned as a result of this finding inasmuch as our testing did not reveal any unallowable costs, and the vendor in question was not actually suspended or debarred. Recommendation. We recommend that the City complete a search on sam.gov and document the results of that search in the vendor file or require the vendor to sign a certification that they are neither suspended nor debarred as part of new contracts for covered transactions to determine if a particular vendor has any active exclusions from participating in federal award programs during the initial bidding process, as required of the Uniform Guidance, and again on an annual basis for best practice. View of Responsible Officials. Management concurs with this finding.