Finding Text
Finding #SA2024-001: Suspension and Debarment Documentation for Contracts and Subcontracts Assistance Listing Number: 21.027 Assistance Listing Title: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Name of Federal Agency: Department of the Treasury Pass Through Entity: County of San Mateo Federal Award Identification Number: SFLRP0201 Criteria: The City’s agreements with the grantor for the Opportunity Coastside Center (Exhibit E) and Affordable Housing Projects (Exhibit C) require the City to comply with 2 C.F.R. Part 180, subpart C, which requires the City to check SAM exclusions, or collect a certification, or add a clause or condition before entering into a covered transaction. Exhibits E and C also include the requirement that the City include “a requirement to comply with these [suspension and debarment] regulations in any lower tier covered transactions it enters into.” Condition: We selected four contracts related to the Opportunity Coastside Center project and the subgrant agreement under the Affordable Housing project to test compliance with the suspension and debarment contract provisions and noted that none of the five contracts/agreements included the provisions required by the grant agreements and the City did not have documentation that it had checked for SAM exclusions. We did note that as of June 23, 2025, none of the five entities was included on the exclusions list on SAM.gov. Effect: The City is not in compliance with the suspension and debarment provisions of the grant award agreements. Cause: We understand City staff checks the SAM.gov for exclusions at the time of contract execution, but documentation is not retained. In addition, we understand the contracts did not include the required suspension and debarment provisions in the contracts due to staff oversight. Recommendation: The City should develop procedures to retain documentation of the check for SAM exclusions prior to entering into contracts, and the City should ensure that all contracts funded by the grants include the requirement that the vendor/subrecipient comply with the suspension and debarment regulations. View of Responsible Officials and Planned Corrective Actions: Please see Corrective Action Plan separately prepared by the City.