Finding 1182583 (2025-006)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2025
Accepted
2026-03-25

AI Summary

  • Core Issue: The City failed to verify vendor eligibility for three out of five vendors tested, risking noncompliance with federal regulations.
  • Impacted Requirements: Non-federal entities must check for suspension and debarment using SAM.gov and maintain proper documentation.
  • Recommended Follow-Up: The City should review all contracts to ensure compliance documentation is obtained for vendors using SLRF funds.

Finding Text

2025-006 U.S. Department of Treasury, Assistance Listing #21.027, Coronavirus State and Local Fiscal Recovery Funds (SLRF) Program for the period of July 1, 2024, through June 30, 2025 Criteria: In accordance with 2 CFR part 180 and 2 CFR §200.214, non-federal entities are prohibited from entering into contracts or making subawards to parties that are suspended or debarred from participation in federal programs. Entities must verify vendor eligibility through the System of Awards Management (SAM.gov), obtain a vendor certification documenting compliance, or add a clause or condition in the contract for that vendor. Condition: Of the five vendors tested, three did not have documented evidence the City performed the required suspension and debarment verification. Cause: The City uses SLRF funds to fill budget gaps caused by the pandemic’s economic fallout. The City did not procure all contracts with the expectation they would be paid for with federal funds. Therefore, suspension and debarment procedures were not verified in all cases. Effect: Without proper verification, there is an increased risk that federal funds could be expended on vendors who are suspended or debarred, which may result in noncompliance with federal regulations and potential repayment of funds. Recommendation: We recommend the City review their existing contracts to ensure documentation of suspension and debarment compliance has been obtained for all vendors paid with SLRF grants. Questioned Costs: None.

Corrective Action Plan

Management response/corrective action plan: Some ARPA expenditures are the result of prior procurements, ongoing contracts, or cooperative purchasing agreements that did not require verification of SAM certification, but were eligible for ARPA funding. Formal bidding includes adding federal language to solicitations and receiving confirmation of active SAM registration. For informal procurements, City departments have been instructed on the requirements when spending grant funds. The City receives federal grant funds regularly for specific projects and understands the federal contracting requirements.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 1182579 2025-005
    Material Weakness Repeat
  • 1182580 2025-006
    Material Weakness Repeat
  • 1182581 2025-006
    Material Weakness Repeat
  • 1182582 2025-006
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds $2.81M
84.027 Special Education State Grants Individuals with Disabilities Act $1.19M
20.507 Federal Transit Formula Grants $639,606
16.922 Equitable Sharing Program $621,080
84.010 Title IA, Disadvantaged $587,519
10.555 NATIONAL SCHOOL LUNCH PROGRAM $552,306
14.218 CDBG - Entitlement Community (CDBG - Entitlement Grants Cluster) $472,899
97.036 FEMA Disaster Relief Grant $447,030
10.553 Breakfast Program $212,227
84.367 Title IIA, Supporting Effective Instruction $205,128
10.555 Food Donation Program $160,266
84.425 COVID-19 - Summer Reservation Subgrant $144,539
84.365 Title III, English Language Acquisition Grant $96,875
84.425 COVID-19 - Literacy Grant $94,539
93.276 Drug Free Communities Support Program (2025 Grant) $93,719
21.027 COVID-19 Workforce Development Admin $83,068
84.424 Title IV, Student Support and Academic Enrichment Program $77,496
84.196 McKinney-Vento Education for Homeless Children and Youth $70,931
20.507 COVID-19 - Federal Transit Formula Grants $50,820
97.039 FEMA Disaster Relief Grant $47,038
84.022 Integrated English Literacy and Civices Education $46,337
97.067 Homeland Security Grant Program- FY 23 $42,550
97.067 Homeland Security Grant Program- FY 22 $39,022
66.818 Brownfields Multipurpose $37,577
84.425 COVID-19 - Maine Outdoor Learning Initiative $36,955
10.559 Summer Food Service Program $35,691
66.458 Clean Water State Revolving Fund - 2024 CWSRF Grant $33,712
84.002 Adult Basic Education $32,922
93.276 Drug Free Communities Support Program (2024 Grant) $30,914
10.582 Fresh Fruit and Vegetables $27,888
97.067 Homeland Security Grant Program- FY 19 $22,567
97.067 Homeland Security Grant Program- FY 21 $21,972
16.738 Justice Assistance Grant $20,018
21.027 COVID-19 Extended Learning Opportunities (SEELO) $15,127
97.044 FEMA Assistance to Firefighters Grant $12,542
20.600 State and Community Highway Safety - Speed Enforcement $10,221
84.173 Preschool $8,180
11.419 Coastal Zone Management Administration $7,932
97.004 County Hazmat Grant $6,708
10.185 Local Food for School Cooperative Agreement $6,495
20.600 State and Community Highway Safety - Impaired Driving $4,922
21.027 COVID-19 Workforce Development $4,002
20.600 State and Community Highway Safety - DRE Forensic $817
10.558 Child and Adult Care Food Program $178