Finding 1228564 (2024-002)

2024-002 – Procurement, Suspension, and Debarment Condition: The District did not have an established policy or procurement protocol in place to ensure vendor verification through one of the three methods defined in federal compliance requirements. Cause: This condition appears to be the result of a lack of internal controls designed to ensure compliance with Uniform Guidance. Auditor Recommendation: We recommend that the District update their procurement policies and processes to ensure that suspension and debarment compliance requirements are being met and effective internal controls are in place. Plan of Action: The District updated its procurement policies and procedures to ensure compliance with federal suspension and debarment requirements under Uniform Guidance. The revised procurement policy establishes procedures requiring verification that vendors are not suspended or debarred prior to entering into contracts or making purchases using federal funds. The policy requires the Finance Department to verify vendor eligibility through one of the approved federal methods, including review of the System for Award Management (SAM.gov), obtaining vendor certifications regarding suspension and debarment status, or incorporating suspension and debarment verification language into applicable contracts. Documentation of the verification process will be maintained with procurement records. These procedures are designed to strengthen internal controls over procurement activities and ensure the District maintains compliance with both State and Federal procurement requirements. Date of implementaion: Corrective action was implemented in February 2026 when the District presented an updated Procurement Policy to the Board of Directors, which was formally approved. The revised policy includes procedures to ensure compliance with federal suspension and debarment requirements. Following Board approval, the Finance Department began implementing the updated procedures for vendor verification and maintaining documentation of suspension and debarment checks as part of procurement records. These procedures are now incorporated into the District's procurement processes to ensure ongoing complaicen with federal requirements.