Finding Text
Criteria: When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR Section 180.995 and agency adopting regulations, is not suspended, or debarred or otherwise excluded from participating in the transaction. “Covered transactions” include those procurement contracts for goods and services awarded under non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR Section 180.220. This requirement applies to contracts entered into to procure goods and services with Coronavirus State and Local Fiscal Recovery Funds and the Coronavirus Capital Projects Fund. Condition: The Town of Hopkinton has a procedure in place for verifying that an entity with which it plans to enter into a covered transaction is not suspended, debarred, or otherwise excluded. The Town did not perform the procedure in fiscal year 2025 and does not have documentation to support that the Town verified that the entities in which it entered into covered transactions to procure goods and services with Coronavirus State and Local Fiscal Recovery Funds and the Coronavirus Capital Projects Fund were not suspended or debarred or otherwise excluded from participating in the transaction. . Cause: The Town did not follow established suspension and debarment compliance policies and procedures for federal awards. Effect: Contracts for goods and service that were “covered transactions” were entered into prior to verifying that an entity was not suspended, debarred, or otherwise excluded. Questioned Costs: None Recommendation: We recommend that the Town perform established verification procedures to ensure that an entity with which it plans to enter into a covered transaction is not suspended, debarred, or otherwise excluded and maintain documentation to support the verification process that was performed. The verification can include checking SAM.gov for exclusions, collecting a certification from the entity, or adding a clause or condition to contract with the entity.