Finding Text
Procurement, Suspension and Debarment (Significant Deficiency/Compliance) ALN No. 21.027 – Coronavirus State and Local Fiscal Recovery Funds ALN No. 15.916 – Outdoor Recreation Acquisition, Development and Planning ALN No. 16.922 – Equitable Sharing Program Criteria: The federal awards suspension and debarment compliance requirements prohibit non-federal entities from contracting or making subawards to parties that are suspended, debarred, or otherwise excluded from participating in federally funded programs. Compliance with this requirement may be documented through one of the following: - A sam.gov verification printout; - A written certification from the vendor; or -A clause in the contract requiring the vendor to affirm it is not suspended or debarred. This must be performed prior to entering into covered transactions, including procurements of goods and services equal to or exceeding $25,000. Condition: During our testing of procurement transactions subject to suspension and debarment requirements, we noted the City did not consistently document verification that vendors had not been suspended, debarred or otherwise excluded from federal contracting eligibility. Specifically, we noted no evidence that a sam.gov exclusions check was conducted, that written vendor certification was obtained, or that the contract documents included the required suspension and debarment clauses. As a result, the City could not demonstrate compliance with suspension and debarment requirements. The following exceptions were noted in our testing: ALN No. 21.027 – For 15 of the 16 vendors tested that were subject to this requirement, evidence of the City verifying that vendors were not suspended or debarred could not be provided. ALN No. 15.916 – For 1 of the 2 vendors tested that were subject to this requirement, evidence of the City verifying that vendors were not suspended or debarred could not be provided. ALN No. 16.922 – For 2 of the 2 vendors tested that were subject to this requirement, evidence of the City verifying that vendors were not suspended or debarred could not be provided. Effect: Failure to verify and document suspension and debarment status increases the risk that federal funds could be expended with vendors who are suspended or debarred from participating in federally funded programs. Cause: The City did not have adequate internal controls in place to ensure suspension and debarment verification was performed and documented for all federally funded procurements. Recommendation: We recommend the City strengthen internal controls over procurement and vendor eligibility by implementing a formal procedure requiring staff to verify suspension and debarment status before entering into any covered transaction equal to or greater than $25,000. This verification should be conducted before entering into the transactions and evidence of such review should be retained to support compliance with the requirement. Repeat Finding from Prior Year(s): N/A Views of Responsible Officials: See management’s corrective action plan.