Finding 1228601 (2025-005)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2025
Accepted
2026-09-01
Audit: 410242
Organization: City of Olathe, Kansas (KS)

AI Summary

  • Core Issue: The City lacks proper controls to verify that vendors are not suspended or debarred before contracts are signed.
  • Impacted Requirements: This violates 2 CFR Part 200, which mandates checks on contractor eligibility to prevent noncompliance.
  • Recommended Follow-Up: Implement a review process to ensure all contractors are verified against suspension and debarment lists before any agreements are made.

Finding Text

Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement, suspension, and debarment. Non-federal entities are prohibited from contracting with or making subawards under covered transactions that are suspended or debarred. Before entering into a covered transaction, the entity must verify that the contractor is not suspended, 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. The City did not retain documentation that the suspension and debarment status of contractors were verified prior to entering into the contract. Questioned costs: None Context: During our testing, it was noted that adequate suspension and debarment documentation was not maintained for one out of five vendors that required suspension and debarment checks. Cause: The City’s controls were not sufficient to ensure that contractors’ suspension and debarment status was documented prior to entering into the contract. Effect: The City could have entered into an agreement with a contractor that was suspended or debarred. Although the City was able to demonstrate that contracts were not entered into with vendors who were suspended or debarred, the absence of documentation performed prior to contract execution presents a risk of noncompliance with applicable procurement regulations. Repeat Finding: This is not a repeat finding. Recommendation: We recommend the City design controls to ensure an adequate review process is in place to review potential contractors to determine they are not suspended or debarred prior to entering into transactions with contractors. Views of responsible officials: There is no disagreement with the audit finding.

Corrective Action Plan

Action taken in response to finding: The City recognizes the importance of ensuring that the required checks are performed and that sufficient evidence of those checks is retained in the procurement files. After receiving this finding in the 2024 audit, the City implemented standard operating procedures for suspension and debarment checks related to purchases involving federal funds. Unfortunately, that procedure did not prevent this finding from occurring due to vendors being used that had already previously been under contract with the City for other projects and services unrelated to federal awards. To correct this issue moving forward, the City will take the following actions: 1) Perform a suspension and debarment check on all vendors currently associated with City contracts. The results of these checks will be documented and maintained in the vendor files with the City’s ERP system, providing a centralized record of the City’s compliance review. 2) Perform an annual suspension and debarment review of all vendors in the City’s ERP system. This process will ensure ongoing controls and compliance, confirming that all vendors within the City’s financial system are not currently suspended or debarred. 3) Perform a suspension and debarment check for all new vendors. Before a new vendor is created within the financial system, a suspension and debarment check will be performed. 4) Continue annual federal grants management training. All employees that have responsibility for managing federal funds will be required to attend a federal grants management training to ensure all employees managing contracts or projects paid for with federal funds understand the latest rules and regulations for compliance. Name(s) of the contact person(s) responsible for corrective action: Jamie Robichaud and Lucas Mellinger Planned completion date for corrective action plan: December 31, 2026

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 1228598 2025-005
    Material Weakness Repeat
  • 1228599 2025-005
    Material Weakness Repeat
  • 1228600 2025-005
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
14.871 SECTION 8 HOUSING CHOICE VOUCHERS $4.93M
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $1.79M
97.083 STAFFING FOR ADEQUATE FIRE AND EMERGENCY RESPONSE (SAFER) $1.27M
20.205 HIGHWAY PLANNING AND CONSTRUCTION $650,000
14.850 PUBLIC HOUSING OPERATING FUND $574,336
14.251 ECONOMIC DEVELOPMENT INITIATIVE, COMMUNITY PROJECT FUNDING, AND MISCELLANEOUS GRANTS $404,717
14.218 COMMUNITY DEVELOPMENT BLOCK GRANTS/ENTITLEMENT GRANTS $287,451
93.493 CONGRESSIONAL DIRECTIVES $103,350
20.939 SAFE STREETS AND ROADS FOR ALL $59,883
16.738 EDWARD BYRNE MEMORIAL JUSTICE ASSISTANCE GRANT PROGRAM $54,009
20.600 STATE AND COMMUNITY HIGHWAY SAFETY $40,442
10.727 INFLATION REDUCTION ACT URBAN & COMMUNITY FORESTRY PROGRAM $19,383
20.616 NATIONAL PRIORITY SAFETY PROGRAMS $10,575
20.327 RAILROAD CROSSING ELIMINATION $8,137
16.710 PUBLIC SAFETY PARTNERSHIP AND COMMUNITY POLICING GRANTS $6,198
14.872 PUBLIC HOUSING CAPITAL FUND $4,819
20.200 HIGHWAY RESEARCH AND DEVELOPMENT PROGRAM $4,500