Finding 1227470 (2025-003)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2025
Accepted
2026-08-20
Audit: 409505
Organization: CITY OF TWO RIVERS (WI)

AI Summary

  • Core Issue: The City lacks adequate internal controls to verify that vendors are not suspended or debarred before entering contracts.
  • Impacted Requirements: This finding relates to compliance with 2 CFR 200.320, which mandates verification of vendor eligibility.
  • Recommended Follow-Up: The City should review and enhance its policies and procedures to ensure compliance with suspension and debarment requirements.

Finding Text

2025-003 Federal Agency: U.S. Department of Environmental Protection Agency Federal Program Name: Capitalization Grants for Drinking Water State Revolving Funds Assistance Listing Number: 66.468 Pass Through Entity: Wisconsin Department of Administration Federal Award Notification Number and Year: 4920-49 and 4920-51 – 2025 Award Period: January 1, 2025 – December 31, 2025 Compliance Requirement Affected: Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: 2 CFR 200.320 Methods of Procurement state that when a nonfederal entity enters into a covered transaction with an entity at a lower tier, the nonfederal entity must verify that the entity, as defined by 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: During our testing, we noted the City did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None Context: During our testing, it was noted that the City was not reviewing vendors prior to entering a contract to ensure the vendor was not on the suspended or debarred vendor list maintained by the General Services Administration. Cause: The City does not have controls related to ensuring suspension and debarment are verified prior to entering a contract with vendors. Effect: The auditor noted no instances of noncompliance with the provisions of procurement, suspension and debarment; however, the lack of internal controls over these compliance requirements provides an opportunity for noncompliance. Repeat Finding: No Recommendation: We recommend the City evaluate its existing policies and procedures to determine where additional enhancements should be made or now policies created. Views of Responsible Officials: There is no disagreement with this finding.

Corrective Action Plan

2025-003 Suspension and Debarment – Assistance Listing Number 66.468 Recommendation: We recommend the City evaluate its existing policies and procedures to determine where additional enhancements should be made or new policies created to ensure vendors are not suspended or debarred. Explanation of disagreement with audit finding: There is no disagreement with the finding. Action planned in response to finding: The City immediately began reviewing its policy related to suspension and debarment and is reviewing procedures to ensure that requirements are consistently followed in future years. Name(s) of the contact person(s) responsible for corrective action: Kassandra Paider, Finance Director Planned completion date for corrective action plan: The City immediately began evaluating procedures and will implement as soon as possible. If the granting agencies have questions regarding this schedule, please call Kassandra Paider, Finance Director, at (920) 793-7274.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 1227469 2025-003
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
66.468 DRINKING WATER STATE REVOLVING FUND $631,293
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $495,796
11.419 COASTAL ZONE MANAGEMENT ADMINISTRATION AWARDS $25,404