Finding Text
Finding Reference: 2024-007 – I. Procurement, Suspension and Debarment Federal Program Information Federal Agencies: Department of Treasury Awards: Assistance Listing 21.027 – COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Award Periods: July 1, 2023 – December 31, 2026 Description: Evidence of controls over Suspension and Debarment Criteria In accordance with Title 2 U.S. Code of Federal Regulations, Part 200.303, Internal controls, “The Non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition As part of our testing over the operating effectiveness of internal controls over the Procurement, Suspension and Debarment assertion for our major programs, we noted that the Corporation did not have appropriately designed internal controls in order to retain evidence related to the completeness and accuracy of the vendor list and monthly results for suspension and debarment. The Corporation validates that vendors are reviewed on a monthly basis to ensure they are not included on the suspension and debarment list. There was no documentation retained to support the vendor list and results were complete and accurate for the monthly validation. Cause The Corporation did not retain sufficient evidence to support the completeness and accuracy of the vendor list and results for suspension and debarment. Effect or potential effect The vendor list and monthly results for suspension and debarment may not be complete and accurate and therefore, vendors used for federally funded activities may be suspended or debarred and result in noncompliance with the requirement. Questioned costs None. Identification of a repeat finding This is not a repeat finding. Context As part of the suspension and debarment testing, we did not identify any vendors that were excluded from the vendor list, monthly results or included within the suspension and debarment list. Management retained evidence of the monthly review including their documentation of follow ups on any vendors that required further investigation. Recommendation The Corporation should retain documentation to support completeness and accuracy of the vendor list submitted for screening and the results obtained to support the screening process to ensure that no suspended or debarred vendors are utilized by the Corporation prior to entering into transactions. View of responsible officials There is no disagreement with the audit finding.