Finding Text
2024-002 – U.S. Environmental Protection Agency, Assistance Listing #66.468 and U.S. Department of Treasury, Assistance Listing #21.027, For the Period January 1, 2024, through December 31, 2024,– Internal Controls Over Procurement, Suspension, and Debarment for Capitalization Grants for Drinking Water State Revolving Funds and Coronavirus State and Local Fiscal Recovery Funds Criteria: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended, debarred, or otherwise excluded from participating in the transaction. In addition, under the requirements of fiscal management, grant recipients are required to design and implement internal controls to ensure compliance with grant requirements and their own policies and procedures. Condition: The District contracted with entities for certain capital projects and did not document that the contractors were not suspended or debarred. Additionally, the District has no written procurement policy that encompasses all requirements of the Uniform Guidance. Cause: Informal procedures regarding purchasing and contracting. Effect: The risk that the District is utilizing federal funds and contracting with suspended, debarred, or other unqualified entities is increased. Questioned Costs: None Recommendation: Management should review the Uniform Guidance procurement standards and develop and adopt a written policy that has all the required elements under Uniform Guidance. Additionally, documentation of suspension and debarment checks should be maintained annually for all vendors for which suspension and debarment requirements apply.