Finding 1236131 (2026-004)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2026
Accepted
2026-09-23
Audit: 411757
Organization: ONEKAMA VILLAGE OF (MI)
Auditor: UHY LLP

AI Summary

  • Core Issue: The Village lacks procedures to verify that contractors are not suspended or debarred, risking noncompliance with federal regulations.
  • Impacted Requirements: Compliance with 2 CFR Section 180.300, which mandates verification of contractor eligibility for federal transactions.
  • Recommended Follow-Up: The Village Council should update policies to include verification controls for all contractors, not just those for federal projects, to ensure compliance moving forward.

Finding Text

2026-002 Suspension and Debarment Program Title: Water and Waste Disposal Systems for Rural Communities Assistance Listing Number: 10.760 Federal Agency: U.S. Department of Agriculture (USDA) Federal Award Number: N/A Federal Award Year: Fiscal year 2026 Pass-Through Entities: N/A Type of Compliance: Material weakness in Internal Controls over Compliance and material noncompliance. Criteria: Per 2 CRF Section 180.300, recipients must have procedures in place for verifying that an entity with which they plan to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Condition: The Village had no control procedures in place for ensuring contractors performing work on federal projects were not suspended or debarred. Cause: There were no controls in place to ensure vendors are not suspended, debarred, or otherwise excluded. Effect: The Village risks entering into contracts with excluded parties, which would be considered noncompliance with the Uniform Guidance. Questioned Costs: None. Although there was no verification that the contractors were not suspended or debarred prior to the audit, a subsequent check was performed to verify the vendor was not suspended or debarred. Perspective Information: The finding appears to be an isolated instance. No sampling was necessary to determine this finding. Identification of Repeat Findings: None Recommendations: The Village Council should, as soon as possible, update its policies to include controls for verifying contractors are not suspended or debarred. Although this is a requirement only for contracts involving the use of federal funds, the Village may want to update its policies over all procurements, not just those related to federally funded projects. Views of Responsible Officials: The Village's engineer has searched the state procurement office webpage to check if any vendor for a federal project is on the debarment list, which they are not. In the future, as part of Federal Grant Funding implementation, the Village will ensure that vendors are not debarred or suspended from federal funding awards, whether they check the list themselves or have the engineer do it as part of the bidding process and retain proper documentation.

Corrective Action Plan

This finding is due to the Village not having control procedures in place for ensuring contractors performing work on federal projects were not suspended or debarred. Subsequently, the Village's engineer has searched the state procurement office webpage to check if any vendor for a federal project is on the debarment list, which they are not. In the future, the Village will have controls in place to ensure that vendors are not debarred or suspended from federal funding awards. The person responsible for the corrective action is the Village President. The anticipated completion date of the corrective action plan is before the end of the 2027 fiscal year. The plan for adherence is the Council will review and implement controls to ensure that vendors are not suspended, debarred, or otherwise excluded.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 1236130 2026-003
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
10.760 WATER AND WASTE DISPOSAL SYSTEMS FOR RURAL COMMUNITIES $1.36M