Finding 1172735 (2023-003)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2023
Accepted
2026-02-06
Audit: 386023
Organization: Town of Guilderland (NY)

AI Summary

  • Core Issue: The Town is not verifying vendor eligibility for Federal assistance programs, violating 2 CFR Section 200.213.
  • Impacted Requirements: Non-compliance with procurement procedures outlined in 2 CFR Section 200.318 and 200.213.
  • Recommended Follow-Up: The Town should implement a review process for vendor eligibility before fund disbursement to ensure compliance.

Finding Text

Coronavirus State and Local Fiscal Recovery Funds Information on Federal Program: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing No. 21.027. Criteria: CFR Section 200.318 stipulates that a non-Federal entity must use its own documented procurement procedures which reflect applicable state, local, and tribal laws, and regulations, provided that the procurements conform to applicable Federal law and the standards identified in Part 200 Subpart D. additionally, 2 CFR Section 200.213 stipulates that no awards, subawards, or contracts be awarded to parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Statement of Condition: During our discussions with management and testing of the major program, we noted that the Town is not verifying the eligibility of vendors to participate in Federal assistance programs. Statement of Cause: The Town did not review compliance requirements related to procurement outlined in 2 CFR Section 200.318 and Section 200.213. Statement of Effect: The Town is not in compliance with 2 CFR Section 200.213. The Town is not performing required procedures, as a result, vendors that are not eligible for participation in Federal assistance programs or activities could be selected. Questioned Cost: None. Repeat Finding: No. Perspective Information: As part of testing of compliance over procurement, a selection of vendors charged to the major program was selected for testing of compliance. Of the Town’s vendors charged to the program, none were suspended or debarred from participation in Federal assistance programs or activities. Recommendation: we recommend that the Town review the requirements of 2 CFR Section 200.213 and ensure that a review of the eligibility of potential vendors to participate in Federal assistance programs or activities is performed prior to disbursing funds to the vendor. Views of responsible officials and Planned Corrective Actions: Moving forward, the Town of Guilderland will ensure that vendors are not included on the suspended or debarred list to ensure compliance with the requirements noted above.

Corrective Action Plan

Finding Reference: 2023-003 Coronavirus State and Local Fiscal Recovery Funds Description: During our discussions with management and testing of the major program, we noted that the Town is not verifying the eligibility of vendors to participate in Federal assistance programs. Recommendation: We recommend that the Town review the requirements of 2 CFR Section 200.213 and ensure that a review of the eligibility of potential vendors to participate in Federal assistance programs or activities is performed prior to disbursing funds to the vendor. Corrective Action: Moving forward, the Town of Guilderland will ensure that vendors are not included on the suspended or debarred list to ensure compliance with the requirements noted above. Person(s) Responsible for Corrective Action: Darci Efaw, Comptroller & Jessica Gulliksen, Fiscal Officer Anticipated Completion Date for Corrective Action: The practice noted above was implemented during September of 2024.

Categories

Procurement, Suspension & Debarment Eligibility Subrecipient Monitoring

Other Findings in this Audit

  • 1172731 2023-001
    Material Weakness Repeat
  • 1172732 2023-001
    Material Weakness Repeat
  • 1172733 2023-002
    Material Weakness Repeat
  • 1172734 2023-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $1.32M
14.871 SECTION 8 HOUSING CHOICE VOUCHERS $1.03M
20.205 HIGHWAY PLANNING AND CONSTRUCTION $847,204
14.896 FAMILY SELF-SUFFICIENCY PROGRAM $67,897
97.036 DISASTER GRANTS - PUBLIC ASSISTANCE (PRESIDENTIALLY DECLARED DISASTERS) $43,484
20.600 STATE AND COMMUNITY HIGHWAY SAFETY $7,247
16.607 BULLETPROOF VEST PARTNERSHIP PROGRAM $2,348