Finding 1205575 (2025-005)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2025
Accepted
2026-03-31
Audit: 397280
Organization: County of San Joaquin (CA)

AI Summary

  • Core Issue: The County failed to verify vendor eligibility against suspension and debarment regulations before transactions.
  • Impacted Requirements: Compliance with § 180.300 of 2 CFR Part 180, which mandates checks against SAM Exclusions.
  • Recommended Follow-Up: Implement procedures for compliance, provide training, and ensure documentation of vendor checks is maintained.

Finding Text

2025-005-Suspension and Disbarment Federal Agency: U.S. Department of Agriculture Federal Program Name: Supplemental Nutrition Assistance Program (SNAP) Assistance Listing Number: 10.561 Type of Finding: Significant Deficiency in Internal Control Over Compliance Criteria: According to § 180.300 of Subpart C - Responsibilities of Participants Regarding Transactions Doing Business with Other Persons of 2 CFR Part 180, when you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Condition: The County did not follow suspension and debarment regulation and suspension and debarment verification procedures. Questioned Costs: None Context: We selected a sample of 8 items as part of our testing over Suspension and Disbarment. Of the 8 items selected, the County was unable to provide proof of suspension and disbarment checks for 6 of the items. Cause: The County has policies that require that the departments verify vendors through Sam.gov prior to entering transactions. However, the policy does not include documentation of these checks. Effect: Without checking debarment before engaging in services, the County could have entered into an agreement with a vendor that was disbarred from receiving federal funding. Repeat Finding: No Recommendation: We recommend that the County should implement procedures to ensure that federal guidance is followed relating to suspension and disbarment and providing training on these procedures, which should include maintaining documentation of the review performed by the County. View of Responsible Officials: There is no disagreement with the audit finding.

Corrective Action Plan

The County has enhanced its procedures to ensure that SAM.gov verification is both performed and documented. Moving forward, County departments will be required to retain a screen print or PDF of the SAM.gov search as part of the procurement file. Additionally, the County’s Purchasing Department will review all procurement files to ensure that the SAM.gov verification is completed and documented.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 1205576 2025-003
    Material Weakness Repeat
  • 1205577 2025-004
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $29.10M
10.561 STATE ADMINISTRATIVE MATCHING GRANTS FOR THE SUPPLEMENTAL NUTRITION ASSISTANCE PROGRAM $16.29M
93.563 CHILD SUPPORT SERVICES $14.55M
11.307 ECONOMIC ADJUSTMENT ASSISTANCE $3.97M
93.323 EPIDEMIOLOGY AND LABORATORY CAPACITY FOR INFECTIOUS DISEASES (ELC) $3.32M
10.569 EMERGENCY FOOD ASSISTANCE PROGRAM (FOOD COMMODITIES) $2.41M
93.959 BLOCK GRANTS FOR PREVENTION AND TREATMENT OF SUBSTANCE ABUSE $2.27M
10.557 WIC SPECIAL SUPPLEMENTAL NUTRITION PROGRAM FOR WOMEN, INFANTS, AND CHILDREN $2.15M
93.659 ADOPTION ASSISTANCE $1.99M
93.268 IMMUNIZATION COOPERATIVE AGREEMENTS $1.76M
93.958 BLOCK GRANTS FOR COMMUNITY MENTAL HEALTH SERVICES $1.76M
93.556 MARYLEE ALLEN PROMOTING SAFE AND STABLE FAMILIES PROGRAM $1.76M
93.090 FEDGAP $1.24M
93.667 SOCIAL SERVICES BLOCK GRANT $1.05M
17.258 WIOA ADULT PROGRAM $1.04M
20.106 AIRPORT IMPROVEMENT PROGRAM, INFRASTRUCTURE INVESTMENT AND JOBS ACT PROGRAMS, AND COVID-19 AIRPORTS PROGRAMS $1.01M
84.126 REHABILITATION SERVICES VOCATIONAL REHABILITATION GRANTS TO STATES $946,010
93.069 PUBLIC HEALTH EMERGENCY PREPAREDNESS $935,749
93.044 SPECIAL PROGRAMS FOR THE AGING, TITLE III, PART B, GRANTS FOR SUPPORTIVE SERVICES AND SENIOR CENTERS $933,311
17.259 WIOA YOUTH ACTIVITIES $868,237
14.218 COMMUNITY DEVELOPMENT BLOCK GRANTS/ENTITLEMENT GRANTS $850,420
93.045 SPECIAL PROGRAMS FOR THE AGING, TITLE III, PART C, NUTRITION SERVICES $823,297
93.569 COMMUNITY SERVICES BLOCK GRANT $787,417
16.575 CRIME VICTIM ASSISTANCE $774,370
10.187 THE EMERGENCY FOOD ASSISTANCE PROGRAM (TEFAP) COMMODITY CREDIT CORPORATION ELIGIBLE RECIPIENT FUNDS $761,876
93.495 COMMUNITY HEALTH WORKERS FOR PUBLIC HEALTH RESPONSE AND RESILIENT $666,681
17.264 NATIONAL FARMWORKER JOBS PROGRAM $596,184
93.674 JOHN H. CHAFEE FOSTER CARE PROGRAM FOR SUCCESSFUL TRANSITION TO ADULTHOOD $562,464
93.493 CONGRESSIONAL DIRECTIVES $558,285
93.645 STEPHANIE TUBBS JONES CHILD WELFARE SERVICES PROGRAM $504,410
10.182 PANDEMIC RELIEF ACTIVITIES: LOCAL FOOD PURCHASE AGREEMENTS WITH STATES, TRIBES, AND LOCAL GOVERNMENTS $396,000
93.052 NATIONAL FAMILY CAREGIVER SUPPORT, TITLE III, PART E $375,428
97.067 HOMELAND SECURITY GRANT PROGRAM $353,508
10.568 EMERGENCY FOOD ASSISTANCE PROGRAM (ADMINISTRATIVE COSTS) $345,700
93.994 MATERNAL AND CHILD HEALTH SERVICES BLOCK GRANT TO THE STATES $318,173
93.889 NATIONAL BIOTERRORISM HOSPITAL PREPAREDNESS PROGRAM $280,987
97.042 EMERGENCY MANAGEMENT PERFORMANCE GRANTS $261,559
93.150 HOMELESS FEDERAL BLOCK GRANT / PATH $249,275
10.025 PLANT AND ANIMAL DISEASE, PEST CONTROL, AND ANIMAL CARE $245,854
10.766 COMMUNITY FACILITIES LOANS AND GRANTS $227,470
81.042 WEATHERIZATION ASSISTANCE FOR LOW-INCOME PERSONS $218,540
97.039 HAZARD MITIGATION GRANT $218,101
14.241 HOUSING OPPORTUNITIES FOR PERSONS WITH AIDS $208,864
93.053 NUTRITION SERVICES INCENTIVE PROGRAM $190,502
93.977 SEXUALLY TRANSMITTED DISEASES (STD) PREVENTION AND CONTROL GRANTS $176,365
16.710 FY24 COPS TECHNOLOGY AND EQUIPMENT PROGRAM $157,029
93.967 CENTERS FOR DISEASE CONTROL AND PREVENTION COLLABORATION WITH ACADEMIA TO STRENGTHEN PUBLIC HEALTH $156,116
93.116 PROJECT GRANTS AND COOPERATIVE AGREEMENTS FOR TUBERCULOSIS CONTROL PROGRAMS $144,766
16.922 EQUITABLE SHARING PROGRAM $136,038
17.278 WIOA DISLOCATED WORKER FORMULA GRANTS $134,180
93.354 PUBLIC HEALTH EMERGENCY RESPONSE: COOPERATIVE AGREEMENT FOR EMERGENCY RESPONSE: PUBLIC HEALTH CRISIS RESPONSE $130,570
93.917 HIV CARE FORMULA GRANTS $114,743
93.558 TEMPORARY ASSISTANCE FOR NEEDY FAMILIES $107,285
14.239 HOME INVESTMENT PARTNERSHIPS PROGRAM $101,811
16.738 EDWARD BYRNE MEMORIAL JUSTICE ASSISTANCE GRANT PROGRAM $100,600
20.616 NATIONAL PRIORITY SAFETY PROGRAMS $98,909
93.778 GRANTS TO STATES FOR MEDICAID $88,901
14.267 CONTINUUM OF CARE PROGRAM $86,564
93.391 ACTIVITIES TO SUPPORT STATE, TRIBAL, LOCAL AND TERRITORIAL (STLT) HEALTH DEPARTMENT RESPONSE TO PUBLIC HEALTH OR HEALTHCARE CRISES $86,083
93.658 FOSTER CARE TITLE IV-E $86,042
10.170 SAN JOAQUIN COUNTY AGVENTURE (SCBG) $82,543
14.231 EMERGENCY SOLUTIONS GRANT PROGRAM $75,541
16.U01 DRUG ENFORCEMENT ADMIN DOMESTIC CANNABIS ERADICATION $73,299
90.404 HAVA ELECTION SECURITY GRANTS $65,968
93.043 SPECIAL PROGRAMS FOR THE AGING, TITLE III, PART D, DISEASE PREVENTION AND HEALTH PROMOTION SERVICES $65,841
97.011 BOATING SAFETY $55,367
93.042 SPECIAL PROGRAMS FOR THE AGING, TITLE VII, CHAPTER 2, LONG TERM CARE OMBUDSMAN SERVICES FOR OLDER INDIVIDUALS $48,532
95.001 HIGH INTENSITY DRUG TRAFFICKING AREAS PROGRAM $44,683
93.090 KIN-GAP IV-E ADMIN $38,541
20.205 HIGHWAY PLANNING AND CONSTRUCTION $31,002
97.024 EMERGENCY FOOD AND SHELTER NATIONAL BOARD PROGRAM $23,361
10.576 SENIOR FARMERS MARKET NUTRITION PROGRAM $17,500
93.783 MEDICARE TRANSITIONAL DRUG ASSISTANCE PROGRAM FOR STATES $15,950
93.566 REFUGEE AND ENTRANT ASSISTANCE STATE/REPLACEMENT DESIGNEE ADMINISTERED PROGRAMS $11,972
93.041 SPECIAL PROGRAMS FOR THE AGING, TITLE VII, CHAPTER 3, PROGRAMS FOR PREVENTION OF ELDER ABUSE, NEGLECT, AND EXPLOITATION $9,409
93.568 LOW-INCOME HOME ENERGY ASSISTANCE $448