Finding 11993 (2022-001)

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Requirement
I
Questioned Costs
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Year
2022
Accepted
2024-02-07
Audit: 16070
Organization: Metropolitan Transit Authority (TN)
Auditor: Crosslin PLLC

AI Summary

  • Core Issue: MTA failed to obtain Suspension & Debarment certifications for one vendor, risking compliance with federal regulations.
  • Impacted Requirements: All contracts over $25,000 must ensure vendors are not suspended or debarred, including land leases.
  • Recommended Follow-Up: MTA should implement a process to secure and file suspension/debarment certifications for all vendors involved in federal programs.

Finding Text

2022 - 001 – PROCUREMENT AND SUSPENSION AND DEBARMENT Federal Transit Administration Formula Grants Assistance Listing No. 20.507 U.S. Department of Transportation Criteria Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred or whose principals are suspended or debarred. Covered transactions include procurement contracts for goods or services that are expected to equal or exceed $25,000 and all non-procurement transactions (e.g., subawards to subrecipients). Condition and Context We performed testwork on 40 vendors and noted that for one out of 40 vendors tested, there was no Suspension & Debarment certification in the files or any evidence that a review had been performed to verify that the vendor or the vendor’s principals had not been suspended or debarred. Upon discussion with MTA, they obtained the required signed certifications from the vendor prior to the issuance of the fiscal year 2022 audit report. Questioned Costs The cost associated with the one item selected for testing was for one month’s lease payment of $11,333. MTA paid this vendor for six months from a federal grant during fiscal year 2022; therefore, the total questioned cost for the six months totaled $67,988. Federal Transit Administration Formula Grants Assistance Listing No. 20.507 U.S. Department of Transportation Cause The amounts paid to the vendor in question were related to a land lease. MTA was unaware that payments for a land lease fell under the federal suspension and debarment requirements. Effect MTA may have entered into an agreement with a vendor that has been suspended or debarred. Recommendation We recommend that MTA ensure compliance with this regulation as it relates to federal programs for all vendors and should include a requirement that suspension/debarment certifications be obtained and placed in all contract files for all vendors regardless of the type of goods or services provided. Views of Responsible Officials and Planned Corrective Actions See management’s corrective action plan.

Corrective Action Plan

Management’s Corrective Action Plan 2022-001 – PROCUREMENT AND SUSPENSION AND DEBARMENT Corrective Action The Corrective Action Plan to resolve this finding was to have the vendor in question register with SAMS for future verifications and also submit the required notarized self-certification of eligibility documentation. The finding was corrected on September 26, 2022 with the vendor submitting the required signed certifications as well as proof of registration on the SAMS website, which will be monitored by MTA to ensure the propriety of any future payments made to this vendor in question as well as to all other vendors. Anticipated Completion Date September 26, 2022 Name of Contact Person Ed Oliphant, Chief Financial Officer Metropolitan Transit Authority (615) 862-6129

Categories

Procurement, Suspension & Debarment Subrecipient Monitoring

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
20.507 Federal Transit_formula Grants $21.22M
20.513 Enhanced Mobility of Seniors and Individuals with Disabilities $839,121
20.526 Buses and Bus Facilities Formula, Competitive, and Low Or No Emissions Programs $782,955
20.530 Public Transportation Innovation $291,809
20.205 Highway Planning and Construction $157,395
20.505 Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research $101,973