Finding 1217554 (2025-004)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2025
Accepted
2026-06-15
Audit: 403710
Organization: Town of Winthrop, Maine (ME)

AI Summary

  • Core Issue: The Town failed to obtain necessary documentation confirming that vendors were not suspended or debarred before entering into contracts under the ARPA grant.
  • Impacted Requirements: Compliance with Uniform Guidance § 200.214, which mandates checks on vendor eligibility and the establishment of internal controls.
  • Recommended Follow-Up: Implement procedures to verify vendor status against suspension and debarment lists and retain all related documentation with grant records.

Finding Text

2025-004 Department of the Treasury Assistance Listing #21.027 Coronavirus State and Local Fiscal Recovery Funds for the period July 1, 2024, to June 30, 2025 Criteria: Recipients of the Coronavirus State and Local Fiscal Recovery Funds (ARPA) grant are required to follow the Uniform Guidance section § 200.214 Suspension and Debarment. Under that section, grant recipients are restricted from entering into contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in federal awards. The Uniform Guidance also requires grant recipients to develop internal controls to ensure compliance with the grant requirements. Condition: The Town had two significant contracts under the ARPA grant that would have required documentation or certification of suspension and debarment from the vendors, but no documentation was obtained. In addition, the Town did not have procedures in place to ensure compliance with suspension and debarment requirements. Cause: The Town did not document a search of Sam.gov to ensure the vendors were not suspended nor debarred. As an alternative, the Town also did not receive certification from the vendors or any other documentation regarding their suspension and debarment status. Effect: The Town runs the risk that the Town will contract with a vendor that is suspended or debarred. Known Questioned Costs: None Likely Questioned Costs: None Recommendations: The Town should have procedures in place to ensure it does not enter into a contract with a vendor that is suspended or debarred. In addition, any documentation of suspension and debarment status should be retained with the grant documentation.

Corrective Action Plan

Management’s Response/Corrective Action Plan: The Town was unaware of the suspension and debarment requirements under Uniform Guidance §200.214. Upon notification of this finding, the Town has implemented corrective measures to ensure compliance. Effective immediately, the Town will verify all vendors before contract execution by searching SAM.gov to confirm they are not suspended or debarred. Additionally, the Town will require vendors to provide written certification of their suspension and debarment status. Documentation of both the SAM.gov verification and vendor certification will remain with the applicable grant records. These procedures will be incorporated into the Town’s standard procurement practices and will apply to all federally funded projects, including a $1.1 million Congressionally Directed Spending (CDS) award for which the Town awaits receipt.

Categories

Procurement, Suspension & Debarment

Programs in Audit

ALN Program Name Expenditures
21.027 Coronavirus State and Local Fiscal Recovery Funds - COVID $320,692
84.010 Title 1A - Basic Disadvantaged Program $274,659
84.027 Special Education Grants to States $247,377
10.555 National School Lunch Program $144,701
10.553 Breakfast Program $71,811
84.425 ARPA Literacy Grant - COVID $43,376
10.555 National School Lunch Program - Donated Commodities $39,708
14.218 Community Development Block Grant $34,437
10.559 National School Lunch - Summer Food Service $25,966
84.425 ARPA Elementary and Secondary School Emergency Relief Fund (ESSER) 3 - COVID $23,154
84.425 ARPA ESSER Summer Enrichment - COVID $9,700
84.358 Rural and low income $9,134
84.425 ARPA HCY II - COVID $6,018
84.173 Special Education Preschool $4,932
84.425 ARPA Preventing Homelessness - COVID $2,579