Finding Text
2025-003 Suspension and Debarment ALN 21.027 Coronavirus State and Local Fiscal Funds US Department of the Treasury Fiscal Year 2025 Funding Criteria: CFR 180.300 requires the City to ensure vendors and contractors are not disqualified, excluded, or debarred prior to entering into a covered transaction. Per 2 CFR 200.303 requires non-federal entities to establish and maintain effective internal controls. The City should have a process to ensure compliance with 2 CFR 180.300. Condition: The City did not have documented controls over the review of verifying vendors are not debarred or suspended. Cause of the condition: The City completes SAM checks of all vendors however, the City does not have a review process to verify the vendor is not suspended or debarred before a contract or payment with the vendor. Potential effect of condition: The City may have covered transactions with federally debarred vendors. Questioned Costs: None noted. Reported finding is a deficiency in internal control. Recommendation: The City should put controls in place to verify SAM checks before authorizing a contract or a purchase order with a vendor for a covered transaction. Management Response: Management recognizes the importance of compliance with federal suspension and debarment requirements. Management has implemented procedures to ensure compliance with suspension and debarment requirements for federally funded transactions. As part of the procurement process, vendors responding to solicitations for grant-funded projects will be required to provide evidence of active SAM registration and certify that they are not suspended or debarred. In addition, prior to execution of contracts or issuance of purchase orders for covered transactions, management will perform and document an independent SAM.gov verification as part of standard pre-award procedures to confirm vendor eligibility.