Finding 1201190 (2025-006)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2025
Accepted
2026-03-30
Audit: 395857
Organization: Town of Greenwich, Connecticut (CT)
Auditor: RSM US LLP

AI Summary

  • Core Issue: Lack of centralized procurement oversight led to inconsistent checks for vendor suspension and debarment compliance.
  • Impacted Requirements: Non-compliance with 2 CFR Part 200, which mandates verification against SAM.gov for suspended or debarred entities.
  • Recommended Follow-Up: Implement controls to ensure all procurement files include necessary suspension and debarment verifications.

Finding Text

2025-006—Material Weakness, Suspension and Debarment U.S. Department of Agriculture Passed through the State of Connecticut Department of Education Child Nutrition Cluster Assistance Listing Number: 10.553 Program Name: School Breakfast Program Assistance Listing Number: 10.555 Program Name: National School Lunch Program U.S. Department of Treasury Passed through the State of Connecticut Office of Policy and Management Assistance Listing Number: 21.027 Program Name: COVID-19 Coronavirus State and Local Fiscal Recovery Funds U.S. Department of Education Passed through the State of Connecticut Department of Education Special Education Cluster (IDEA) Assistance Listing Number: 84.027 Program Name: Special Education Grants to States Assistance Listing Number: 84.173 Program Name: Special Education Preschool Grants U.S. Department of Transportation Passed through the State Department of Transportation Assistance Listing Number: 20.205 Program Name: Highway Planning and Construction Criteria: 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires compliance with provisions of procurement, suspension, and debarment. Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the nonfederal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: Procurement activities related to federal awards were performed by multiple departments and were not handled through a centralized procurement function. Management was unable to provide documentation demonstrating that vendors subject to suspension and debarment requirements were consistently reviewed against SAM.gov or that vendor certifications were obtained during the audit period. Cause: Procurement responsibilities were decentralized across departments, and management had not assigned responsibility, or implemented oversight procedures to ensure suspension and debarment requirements were addressed consistently for all federally funded procurements. Effect: Documentation of the requirement for suspension and debarment was not maintained. Contracts could be made with entities on the suspended and debarred list. Questioned costs: None. 2025-006—Material Weakness, Suspension and Debarment (Continued) Context: See condition above. There was no documentation for 14 selections tested. Identification as a repeat finding if applicable: 2024-005 Recommendation: We recommend the Town implement specific controls to ensure procurement files include suspension and debarment verification, where required. View of responsible officials: We agree with the finding. See corrective action plan.

Corrective Action Plan

2025-006 Material Weakness and Noncompliance, Suspension and Debarment (Repeat Finding 2024-005) Audit Finding: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards requires compliance with provisions of procurement, suspension, and debarment. Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Documentation that such a verification was done must be maintained. The Town did not have documentation to support verification that three vendors were not excluded from federal contract due to debarment or suspension. Corrective Action Taken: The Town and Board of Education (BOE) have enhanced procurement controls to ensure suspension and debarment verifications are documented in accordance with 2 CFR 200.214. BOE’s Procurement Department routinely reviews SAM.gov to verify suspension and debarment status for all contracts, regardless of the funding source. Moving forward, a verification sheet will be included with all contract documentation. Additionally, BOE personnel involved in the procurement process have received training on applicable federal compliance requirements. The Procurement Department will also require vendors to complete suspension and debarment certification forms, which will be maintained within the Munis system by the Accounting Department. Anticipated Completion Date: In Process as of July 2025. Name and Phone # of Person Responsible for Implementation Joan Lynch, Comptroller, 203-622-2226

Categories

No categories assigned yet.

Other Findings in this Audit

  • 1201176 2025-005
    Material Weakness Repeat
  • 1201177 2025-005
    Material Weakness Repeat
  • 1201178 2025-005
    Material Weakness Repeat
  • 1201179 2025-005
    Material Weakness Repeat
  • 1201180 2025-005
    Material Weakness Repeat
  • 1201181 2025-005
    Material Weakness Repeat
  • 1201182 2025-005
    Material Weakness Repeat
  • 1201183 2025-005
    Material Weakness Repeat
  • 1201184 2025-005
    Material Weakness Repeat
  • 1201185 2025-006
    Material Weakness Repeat
  • 1201186 2025-006
    Material Weakness Repeat
  • 1201187 2025-006
    Material Weakness Repeat
  • 1201188 2025-006
    Material Weakness Repeat
  • 1201189 2025-006
    Material Weakness Repeat
  • 1201191 2025-007
    Material Weakness Repeat
  • 1201192 2025-008
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.027 SPECIAL EDUCATION GRANTS TO STATES $2.96M
20.205 HIGHWAY PLANNING AND CONSTRUCTION $1.07M
10.555 NATIONAL SCHOOL LUNCH PROGRAM $899,624
84.010 TITLE I GRANTS TO LOCAL EDUCATIONAL AGENCIES $619,244
14.218 COMMUNITY DEVELOPMENT BLOCK GRANTS/ENTITLEMENT GRANTS $608,970
20.939 SAFE STREETS AND ROADS FOR ALL $196,819
84.367 SUPPORTING EFFECTIVE INSTRUCTION STATE GRANTS (FORMERLY IMPROVING TEACHER QUALITY STATE GRANTS) $176,291
84.173 SPECIAL EDUCATION PRESCHOOL GRANTS $136,856
10.553 SCHOOL BREAKFAST PROGRAM $109,136
84.048 CAREER AND TECHNICAL EDUCATION -- BASIC GRANTS TO STATES $98,829
84.424 STUDENT SUPPORT AND ACADEMIC ENRICHMENT PROGRAM $60,856
20.601 ALCOHOL IMPAIRED DRIVING COUNTERMEASURES INCENTIVE GRANTS I $53,984
97.044 ASSISTANCE TO FIREFIGHTERS GRANT $46,399
84.365 ENGLISH LANGUAGE ACQUISITION STATE GRANTS $44,042
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $35,000
93.323 EPIDEMIOLOGY AND LABORATORY CAPACITY FOR INFECTIOUS DISEASES (ELC) $21,090
84.425 EDUCATION STABILIZATION FUND $19,475
20.616 NATIONAL PRIORITY SAFETY PROGRAMS $18,836
93.967 CENTERS FOR DISEASE CONTROL AND PREVENTION COLLABORATION WITH ACADEMIA TO STRENGTHEN PUBLIC HEALTH $17,614
97.056 PORT SECURITY GRANT PROGRAM $17,063
10.185 LOCAL FOOD FOR SCHOOLS COOPERATIVE AGREEMENT PROGRAM $15,995
93.069 PUBLIC HEALTH EMERGENCY PREPAREDNESS $15,834
10.579 CHILD NUTRITION DISCRETIONARY GRANTS LIMITED AVAILABILITY $14,109
93.268 IMMUNIZATION COOPERATIVE AGREEMENTS $13,168
16.607 BULLETPROOF VEST PARTNERSHIP PROGRAM $7,778
97.042 EMERGENCY MANAGEMENT PERFORMANCE GRANTS $5,000