Finding Text
Finding 2025-003 – Suspension and Debarment Federal Program: Coronavirus State and Local Fiscal Recovery Funds ALN: 21.027 Compliance Requirement: Procurement, Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Over Compliance Criteria Per 2 CFR §180.300 and 2 CFR §200.214, non-Federal entities are prohibited from entering into covered transactions with parties that are suspended or debarred. Covered transactions are defined in 2 CFR Part 180, Subpart B. Non-Federal entities must verify the suspension and debarment status of participants through the System for Award Management (SAM.gov) or by obtaining certification from the contractor or subrecipient. Condition During testing of procurement and contract files, the Town did not retain documentation demonstrating that contractors were verified against SAM.gov. Additionally, contracts reviewed did not include provisions requiring contractors to certify that they and their subcontractors were not suspended or debarred. Cause The Town does not have a formalized process to ensure verification of contractor eligibility through SAM.gov or inclusion of required suspension and debarment certification language in contracts. Effect Failure to verify contractor eligibility increases the risk that the Town could enter into agreements with suspended or debarred parties, resulting in noncompliance with federal requirements. Questioned Costs None. Repeat Finding No. Recommendation We recommend the Town implement procedures to verify and document contractor eligibility through SAM.gov for all applicable procurements and to include required suspension and debarment certification language in all contracts and subawards. Supporting documentation should be retained in the procurement file. Views of Responsible Officials Management agrees with the finding and will implement procedures to verify contractor eligibility through SAM.gov and retain appropriate documentation in procurement files.