Finding Text
Finding 2022-001 Significant Deficiency: Suspension And Debarment - Control Finding ALN 20.500, 20.507, 20.525, 20.526 - Federal Transit Cluster Federal Agency: Department of Transportation Pass-Through Entity: N/A - Direct Award Criteria Or Specific Requirement: Uniform Guidance, ?200.303 ? Internal Controls, requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal program. Condition: Prior to the execution of a contract, management should verify that the contractor has not been suspended or debarred. Cause: Controls over compliance put in place by management were not operating effectively as it relates to this compliance requirement. Proof of verification that the contractor was not suspended or debarred prior to executing a contract with the vendor was not retained. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance. Questioned Costs: Not applicable. Context: Internal controls as designed by Bi-State Development to ensure that vendors are not suspended or debarred before a contract is executed did not occur. Documentation was not retained in the vendor file for the vendor selected for this compliance test. Statistical sampling was not used to test this compliance requirement. Identification As A Repeat Finding: This finding is a repeat of finding 2021-002 from the prior year?s schedule of findings and questioned costs. Recommendation: We recommend that management review its processes and controls surrounding applicable compliance requirements to improve the existing system such that it will ensure compliance with the requirements of federal grants, and to review all current contracts to verify that required support is present. Views Of Responsible Officials: There is a process in place. We will run this process as designed. The process is for the buyer to check the SAM.gov system for debarment and keep a copy of the record in the procurement file.