Finding Text
Procurement, Suspension & Debarment Criteria – Title 2, U.S. Code of Federal Regulations Part 180.300 When a non-federal entity enters into a covered transaction with an entity at a lower tier, the nonfederal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition – The City’s management did not verify that the vendor was not suspended or disbarred. Cause – The City’s management were not aware that they needed to verify that the entity was not suspended or debarred. Effect – The City did not have a process to indicate that the vendor was not suspended or disbarred from doing business with federal funds. The City is not in compliance with Federal regulations pertaining to procurement suspension & debarment as required by the Uniform Guidance. Recommendation – The City should verify that each vendor or contracts paid with federal awards, are not suspended by checking the System for Awards Management (SAM) Exclusion available at SAM.gov. Response and Corrective Action Planned – The City was unable to check to make sure the contractor was not disbarred from federal grants. The City is working through a process to ensure all contractors are not on the disbarred list. The City will check SAMS numbers and do more work on the front end for each contractor. Conclusion – Response accepted.