Finding Text
2023 – 005 Suspension & Debarment Federal agency: U.S. Treasury Department Federal program title: COVID-19 Coronavirus State and Local Fiscal Recovery Funds FALN Number: 21.027 Federal Award Identification Number: CPAP000000381538 Award Period: March 2021 through December 2024 Type of Finding: • Material Weakness in Internal Control Over Compliance • Other Matters Condition: During our testing, we noted the County did not have internal controls designed to ensure compliance with federal suspension and debarment requirements. Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of suspension and debarment. The County should have internal controls designed to ensure compliance with those provisions. The County is also required to verify an entity is not suspended or debarred. Questioned costs: None Context: During our testing, it was noted that the County did not follow suspension and debarment requirements for 5 of 5 items tested. Cause: The County does not have a policy in place that clearly addresses compliance with federal grant requirements per the Uniform Guidance. Effect: The County lacked reasonable assurance of compliance with suspension and debarment requirements; however, no instances of awards to suspended or debarred parties were identified during audit testing. Repeat finding: Yes, 2022-005 Recommendation: We recommend the County review the federal procurement requirements outlined in the federal Uniform Guidance and create a written policy to address federal compliance requirements. Additionally, we recommend a designated individual at the County ensures purchases made with federal grant funding comply with federal procurement requirements by type of procurement (micropurchase, small purchase, sole-source, etc.) and also suspension and debarment requirements. Views of responsible officials: The Menard County Treasurer will provide appropriate in-house training for federal procurement requirements as relayed in the Uniform Guidance. A written policy will be created and adhered to addressing federal compliance requirements with suspension and debarment requirements.