Finding Text
Federal agency: U.S. Department of Treasury Federal program title: Coronavirus State and Local Fiscal Recovery Funds (SLFRF) Assistance Listing Number: 21.027 Federal Award Identification Number: Unknown Pass-Through Agency: Massachusetts Department of Revenue Pass-Through Number(s): GAE DOR 22ARPALOCPASSTHRU001 Award Period: July 1, 2024 – June 30, 2025 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Compliance Requirement: Suspension and Debarment Criteria or Specific Requirement: The Code of Federal Regulations (CFR) Title 2 Part 200.214 states that nonfederal entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Condition and Context: For one of one vendors tested, documentation was not provided to support that the Town verified the vendor was not suspended or debarred from participation in federal assistance programs or activities. Questioned Costs: None Cause: Procedures were not in place to document the verification that all vendors were not suspended or debarred from participation in federal programs or activities. Effect: While this did not occur in the instance identified in this finding, lack of verification of vendors’ suspension or debarment status could cause federal grant funds to be expended to vendors that are excluded from participation in federal assistance programs or activities. Repeat Finding: No Recommendation: We recommend the Town enhance procedures and controls to ensure that the verification of vendors’ suspension and debarment status is obtained and documented prior to executing transactions. This verification can be performed by checking the System for Award Management (SAM.gov), obtaining a written certification from the vendor, or including a contract clause stating that the vendor is not suspended or debarred. Views of Responsible Officials: Management agrees with the finding.