Finding Text
Condition: Upon inquiry of county personnel and a test of eleven (11) disbursements totaling $1,136,767, the following weaknesses were noted: • The County did not perform required suspension and debarment verifications on vendors for purchases exceeding $25,000. Cause of Condition: Policies and procedures have not been designed and implemented to ensure federal expenditures are made in accordance with federal compliance requirements. Effect of Condition: This condition resulted in noncompliance with grant requirements. Recommendation: OSAI recommends the County gain an understanding of the grant requirements for this program and implement internal controls to ensure compliance with these grant requirements. Management Response: Chairman of the Board of County Commissioners: To correct this issue, the County will develop policy and procedures to ensure compliance requirements with federal funds are identified and the County complies with them. The policy and procedures will be reviewed, adopted, and monitored by the Board of County Commissioners. County Clerk: The County will gain an understanding of the grant requirements for this program and implement internal controls to ensure compliance with these grant requirements. All entities that bid projects under these federal grants will require active and good standing under Sam.gov. Criteria: 2 CFR 180.700 – 180.760 Suspension and 2 CFR 180.800 – 180.885 Debarment reads as follows: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a 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. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215.