Finding Text
Finding 2024-004 – Suspension/Debarment Federal Agency: U.S. Department of Treasury Federal Program: Coronavirus State and Local Fiscal Recovery Funds AL Number: 21.027 Pass-through: City of Columbus and Community Shelter Board Award Number: 2920-2021 and YMCA-24-CSB Award Year: Various Type of Finding: Significant Deficiency and Noncompliance Criteria: Per 2 CFR 200.414, "Recipients and subrecipients are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, as well as 2 CFR part 180. The regulations in 2 CFR part 180 restrict making Federal awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in Federal awards." Per 2 CFR 180 Subpart C, section 300, recommendations to verify that the person or company you intend to do business with is not excluded or disqualified include: (a) Checking SAM.gov Exclusions, (b) Collecting a certification from that person, or (c) Adding a clause or condition to the covered transaction with that person. Condition: The controls in place were not sufficient to ensure vendors the Association transacted with were not debarred, suspended, or otherwise excluded from participating in Federal awards. Context: Out of three vendors selected for testing, the Association did not verify whether they were suspended or debarred from entering into federally covered transactions for any of them. Cause: The Association indicated that they were not familiar with this compliance requirement for this funding. Effect: The Association did not identify the need to verify vendors and therefore did not have any support that they verified vendors for this program. Questioned costs: None. Identification of how questioned costs were computed: Not applicable. Repeat finding: No. Recommendation: The Association should put processes in place that ensures vendors are not suspended or debarred from entering into transactions involving Federal awards and retain documentation of the verification. Views of responsible officials: See Corrective Action Plan.