Finding Text
Federal Grantor: U.S. Department of Treasury; Pass-through Grantor: n/a; Assistance Listing Number: 21.027; Program Title: COVID-19 Coronavirus State and Local Fiscal Recovery Funds; Award Year: 2023; Compliance Requirement(s): (I) - Procurement, Suspension, & Debarment; Known Questioned Costs: $333,416. Criteria: Under Uniform Guidance (2 CFR 200.213) and the OMB Compliance Supplement for Assistance Listing 21.027, recipients must verify that contractors and subrecipients are not suspended, debarred, or excluded before entering into covered transactions. SLFRF recipients are required to follow Treasury guidance and 31 CFR Part 19.300 for exclusions screening. Condition: During a review of procurement files for SLFRF-funded contracts, we noted that four contractors/subrecipients, totaling $333,416, were engaged without any documentation that the auditee performed exclusion checks on SAM.gov or obtained suspension/debarment certifications. Cause: The auditee did not include suspension and debarment verification in its procurement policies or standard review process for SLFRF-covered transactions under Assistance Listing 21.027. Effect: Failure to screen contractors for suspension, debarment, or exclusion risks violation of federal procurement integrity laws. This noncompliance may result in SLFRF funds being paid to ineligible parties, which could constitute an improper expenditure and put the auditee and federal funding at risk. Recommendation: We recommend that the County immediately verify the suspension/debarment status of the four contractors/subrecipients using SAM.gov; if any are excluded, initiate corrective action and recover funds if necessary. The County should revise procurement policies to incorporate mandatory use of exclusion screening (e.g., SAM.gov) and signed certifications before a contract award under SLFRF, and train procurement staff on 2 CFR 200.213, 31 CFR Part 19, and Assistance Listing 21.027 suspension/debarment rules. The County should also implement internal controls, such as periodic audits or checklists, to ensure ongoing compliance with suspension and debarment requirements in future covered transactions. Management's Response: The County will act on the recommendation given and take necessary actions where applicable.