Finding Text
Finding #SA2025-001: Suspension and Debarment Documentation for Contracts and Subcontracts Assistance Listing Number: 21.027 Assistance Listing Title: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Name of Federal Agency: Department of the Treasury Pass Through Entity: County of San Mateo Federal Award Identification Number: SFLRP0201 Criteria: The City’s agreement with the grantor for the Affordable Housing Project (Exhibit C) requires the City to comply with 2 C.F.R. Part 180, subpart C, which requires the City to check SAM exclusions, or collect a certification, or add a clause or condition before entering into a covered transaction. Exhibit C also includes the requirement that the City include “a requirement to comply with these [suspension and debarment] regulations in any lower tier covered transactions it enters into.” Condition: The subgrant agreement under the Affordable Housing project does not include the provisions required by the grant agreement and the City did not have documentation that it had checked for SAM exclusions. We did note that as of July 20, 2026, the subgrantee was not included on the exclusions list on SAM.gov. Effect: The City is not in compliance with the suspension and debarment provisions of the grant award agreement. Cause: We understand City staff checks the SAM.gov for exclusions at the time of contract execution, but documentation is not retained. In addition, we understand the contract did not include the required suspension and debarment provisions due to staff oversight. Identification as a Repeat Finding: Yes, since 2024 (Finding #SA2024-001) Recommendation: The City should develop procedures to retain documentation of the check for SAM exclusions prior to entering into contracts, and the City should ensure that all contracts funded by the grants include the requirement that the vendor/subrecipient comply with the suspension and debarment regulations. View of Responsible Officials and Planned Corrective Actions: Please see Corrective Action Plan separately prepared by the City.