Finding 1225076 (2026-007)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2026
Accepted
2026-07-30
Audit: 408218
Organization: Village of Marion (MI)
Auditor: UHY LLP

AI Summary

  • Core Issue: The Village lacks procedures to verify that contractors for federal projects are not suspended or debarred, leading to a material weakness in internal controls.
  • Impacted Requirements: Compliance with 2 CFR Section 180.300 is necessary to avoid contracting with excluded parties, which could result in noncompliance with Uniform Guidance.
  • Recommended Follow-Up: The Village Council should update policies to include verification controls for all contractors, not just those funded by federal grants, to ensure compliance moving forward.

Finding Text

2026-006 Suspension and Debarment Program Title: Capitalization Grants for Drinking Water State Revolving Fund Assistance Listing Number: 66.468 Federal Agency: U.S. Environmental Protection Agency (EPA) Federal Award Number: N/A Federal Award Year: Fiscal year 2026 Pass-Through Entities: Michigan Department of Environment, Great Lakes, and Energy (EGLE) Type of Compliance: Material weakness in Internal Controls over Compliance and material noncompliance Criteria: Per 2 CRF Section 180.300, recipients must have procedures in place for verifying that an entity with which they plan to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Condition: The Village had no control procedures in place for ensuring contractors performing work on federal projects were not suspended or debarred. Cause: There were no controls in place to ensure vendors are not suspended, debarred, or otherwise excluded. Effect: The Village risks entering into contracts with excluded parties, which would be considered noncompliance with the Uniform Guidance. Questioned Costs: None. Although there was no verification that the contractors were not suspended or debarred prior to the audit, a subsequent check was performed to verify the vendor was not suspended or debarred. Perspective Information: The finding appears to be an isolated instance. No sampling was necessary to determine this finding. Identification of Repeat Findings: 2025-006 Recommendations: The Village Council should, as soon as possible, update its policies to include controls for verifying contractors are not suspended or debarred. Although this is a requirement only for contracts involving the use of federal funds, the Village may want to update its policies over all procurements, not just those related to federally funded projects. Views of Responsible Officials: The Village’s engineer has searched the state procurement office webpage to check if any vendor for a federal project is on the debarment list, which they are not. In the future, as part of Federal Grant Funding implementation, the Village will ensure that vendors are not debarred or suspended from federal funding awards, whether they check the list themselves or have the engineer do it as part of the bidding process and retain proper documentation.

Corrective Action Plan

This finding is due to the Village not having control procedures in place for ensuring contractors performing work on federal projects were not suspended or debarred. Subsequently, the Village’s engineer has searched the state procurement office webpage to check if any vendor for a federal project is on the debarment list, which they are not. In the future, the Village will have controls in place to ensure that vendors are not debarred or suspended from federal funding awards. The person responsible for the corrective action is the Village President. The anticipated completion date of the corrective action plan is before the end of the 2027 fiscal year. The plan for adherence is the Council will review implement controls to ensure that vendors are not suspended, debarred, or otherwise excluded.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 1225075 2026-006
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
66.468 CAPITALIZATION GRANTS FOR DRINKING WATER STATE REVOLVING FUNDS $1.14M