Finding 1221720 (2025-002)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2025
Accepted
2026-06-30
Audit: 405982
Organization: City of South St. Paul (MN)
Auditor: LB CARLSON LLP

AI Summary

  • Core Issue: The City lacks effective internal controls to ensure compliance with federal suspension and debarment requirements for vendors in the Highway Planning and Construction program.
  • Impacted Requirements: Compliance with 2 CFR § 180 and 2 CFR § 200.318-327, which mandates proper checks on vendors to avoid contracting with suspended or debarred parties.
  • Recommended Follow-Up: The City should enhance its internal control procedures, ensuring proper documentation and checks against the federal Excluded Parties List for any contracts over $25,000.

Finding Text

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE – U.S. DEPARTMENT OF TRANSPORTATION – PASSED THROUGH MINNESOTA DEPARTMENT OF TRANSPORTATION – HIGHWAY PLANNING AND CONSTRUCTION FEDERAL ALN 20.205 2025-002 Internal Control Over Compliance With Federal Suspension and Debarment Requirements Criteria – 2 CFR § 180 and 2 CFR § 200.318-327 requires the City to establish and maintain effective internal control over compliance with requirements applicable to federal program expenditures, including suspension and debarment requirements applicable to the Highway Planning and Construction federal program. Condition – During our audit, we noted the City did not have sufficient controls in place within its major federal programs to ensure compliance with federal requirements related to assuring that the City was not contracting for goods or services with parties that are suspended or debarred, or whose principals are suspended or debarred from participating in contracts involving the expenditures of federal program funds. Questioned Costs – None. Our testing did not indicate any instances of noncompliance with this requirement. Context – The City did not obtain the appropriate documentation for three of four vendors tested applicable to the Highway Planning and Construction program to ensure the vendors were not suspended or debarred from participation in federal program contracts. This is not a statistically valid sample. Repeat Finding – This is a current year finding. Cause – This was an oversight by city personnel. Effect – Noncompliance with suspension and debarment requirements could result in the City expending federal funds inappropriately or utilizing vendors that are not eligible to be parties to such transactions, which could be viewed as a violation of the award agreement. Recommendation – We recommend that the City review its internal control procedures relating to suspension and debarment for the Highway Planning and Construction federal program. Internal controls over compliance for this area should include retention of adequate documentation of compliance with Uniform Guidance requirements related to suspension and debarment. These controls should include steps to ensure any vendor with which the City contracts for goods or services exceeding $25,000 is not listed as suspended or debarred on the federal Excluded Parties List System website. View of Responsible Official and Planned Corrective Actions – The City agrees with the finding. The City will review procedures relating to suspension and debarment for its federal programs to ensure compliance with the Uniform Guidance in the future. The City has separately issued a Corrective Action Plan related to this finding.

Corrective Action Plan

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE – U.S. DEPARTMENT OF TRANSPORTATION – PASSED THROUGH MINNESOTA DEPARTMENT OF TRANSPORTATION – HIGHWAY PLANNING AND CONSTRUCTION FEDERAL ALN 20.205 2025-002 Internal Control Over Compliance With Federal Suspension and Debarment Requirements Finding Summary 2 CFR § 180 and 2 CFR § 200.318-327 requires the City to establish and maintain effective internal control over compliance with requirements applicable to federal program expenditures, including suspension and debarment requirements applicable to the Highway Planning and Construction federal program. During our audit, we noted the City did not have sufficient controls in place within this program to ensure compliance with federal requirements related to assuring that the City was not contracting for goods or services with parties that are suspended or debarred, or whose principals are suspended or debarred from participating in contracts involving the expenditures of federal program funds. Corrective Action Plan Actions Planned – The City has implemented new processes and procedures in 2026 which address this internal control finding to ensure compliance with the Uniform Guidance in the future. The procedures will include steps to assure that City personnel are following the requirements of the Uniform Guidance related to suspension and debarment, including maintaining appropriate documentation. Official Responsible – Clara Hilger, Finance Director. Planned Completion Date – June 30, 2026. Disagreement With or Explanation of Finding – The City agrees with this finding. Plan to Monitor – The City’s Finance Director, Clara Hilger, will oversee the evaluation of this process, and the implementation of any procedural changes deemed necessary to ensure the City’s control procedures over suspension and debarment are performed and adequately documented in the future.

Categories

Procurement, Suspension & Debarment Internal Control / Segregation of Duties Significant Deficiency

Other Findings in this Audit

  • 1221713 2025-001
    Material Weakness Repeat
  • 1221714 2025-001
    Material Weakness Repeat
  • 1221715 2025-001
    Material Weakness Repeat
  • 1221716 2025-001
    Material Weakness Repeat
  • 1221717 2025-001
    Material Weakness Repeat
  • 1221718 2025-001
    Material Weakness Repeat
  • 1221719 2025-001
    Material Weakness Repeat
  • 1221721 2025-001
    Material Weakness Repeat
  • 1221722 2025-001
    Material Weakness Repeat
  • 1221723 2025-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
66.468 DRINKING WATER STATE REVOLVING FUND $2.25M
20.205 HIGHWAY PLANNING AND CONSTRUCTION $1.00M
14.850 PUBLIC HOUSING OPERATING FUND $843,896
14.872 PUBLIC HOUSING CAPITAL FUND $292,115
16.710 PUBLIC SAFETY PARTNERSHIP AND COMMUNITY POLICING GRANTS $240,000
20.106 AIRPORT IMPROVEMENT PROGRAM, INFRASTRUCTURE INVESTMENT AND JOBS ACT PROGRAMS, AND COVID-19 AIRPORTS PROGRAMS $163,258
14.251 ECONOMIC DEVELOPMENT INITIATIVE, COMMUNITY PROJECT FUNDING, AND MISCELLANEOUS GRANTS $134,015
20.600 STATE AND COMMUNITY HIGHWAY SAFETY $4,631
20.608 MINIMUM PENALTIES FOR REPEAT OFFENDERS FOR DRIVING WHILE INTOXICATED $3,679
16.607 BULLETPROOF VEST PARTNERSHIP PROGRAM $3,173