Finding 1206585 (2025-009)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2025
Accepted
2026-04-14
Audit: 398641
Organization: City of Lewistown (MT)

AI Summary

  • Core Issue: The city failed to follow procurement rules, specifically not verifying if contractors were suspended or debarred as required by federal regulations.
  • Impacted Requirements: Non-compliance with 2 CFR §200.318-§200.327, which mandates competitive procurement processes and eligibility checks for contractors.
  • Recommended Follow-Up: Management should create and implement procurement procedures to ensure compliance with federal regulations and prevent contracts with ineligible parties.

Finding Text

NONCOMPLIANCE WITH PROCUREMENT AND SUSPENSION AND DEBARMENT REQUIREMENTS, CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS, ASSISTANCE LISTING No. 21.027, Direct Allocation, MT-ARPA-CG-23-613, RRG-22-1864A, AMC-22-0137, YEAR ENDED JUNE 30, 2025 Criteria: Per 2 CFR 200.214, non-Federal entities are subject to the non-procurement, debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 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: The city did not comply with the procurement standards outlined in 2 CFR §200.318-§200.327, which require competitive procurement processes and verification that contractors are not suspended or debarred. Specifically, the city did not verify the eligibility of program recipients/participants/contractors through the System for Award Management (SAM) or equivalent documentation in order to verify that they were not suspended, debarred, or otherwise excluded from participation in the program. Cause: The city does not have procurement policies and procedures in place that allow it to comply with procurement standards outlined in the Uniform Guidance. Effect: Non-compliance with program terms and conditions. Questioned costs: None. Recommendation: Management should develop procedures that will provide reasonable assurance that procurement of goods and services are made in compliance with applicable federal regulations and other procurement requirements specific to a federal award or subaward, and that no subaward, contract, or agreement for purchase of goods or services is made with any suspended or debarred party. Views of responsible officials and planned corrective actions: The government agrees with this finding and will adhere to the attached corrective action plan.

Corrective Action Plan

NONCOMPLIANCE WITH PROCUREMENT AND SUSPENSION AND DEBARMENT REQUIREMENTS, CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS, ASSISTANCE LISTING No. 21.027, Direct Allocation, MT-ARPA-CG-23-613, RRG-22-1864A, RRG-22-1864A, YEAR ENDED JUNE 30, 2025 Name of contact person: City Manager Corrective Action: The City ensures that debarment requirements for prime contractors and subcontractors are met prior to the use of federal funds. Moving forward, the City will expand compliance efforts to include all required parties. Staff will be educated on these requirements, and the City will work with engineers to ensure debarment language is included in project bidding documents and supplementary conditions. Proposed Completion Date: Immediately

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 1206582 2025-009
    Material Weakness Repeat
  • 1206583 2025-009
    Material Weakness Repeat
  • 1206584 2025-009
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
66.468 DRINKING WATER STATE REVOLVING FUND $199,786
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $162,546
10.675 URBAN AND COMMUNITY FORESTRY PROGRAM $850