Finding Text
Significant Deficiency – Suspended or Debarred Covered Transactions Criteria: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR 180.215. Condition: We noted that the Village did not have procedures in place to ensure that the sub-contractors were not suspended or debarred. Cause: This condition was caused by an oversight by management. Effect: As a result of this condition, the Village did not have controls in place to ensure compliance with the federal program. We did note that none of the contractors used on the Village's project were suspended or debarred. Recommendation: We recommend that the Village implement procedures to monitor contractors and subcontractors for any that are suspended or debarred. View of Responsible Officials: The Village will develop further procedures to ensure contractors used on projects are not suspended or debarred and retain documentation of the Village's contractor verifications.