Finding 1236253 (2024-002)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2024
Accepted
2026-09-23

AI Summary

  • Core Issue: The Cooperative did not verify if vendors in covered transactions were suspended or debarred, violating federal requirements.
  • Impacted Requirements: Non-compliance with suspension and debarment rules under 2 CFR 180 could lead to unauthorized vendor contracts.
  • Recommended Follow-up: Implement internal controls to confirm vendor eligibility before engaging in covered transactions.

Finding Text

Assistance Listing Number 21.029 COVID-19 Coronavirus Capital Projects Fund U.S. Department of the Treasury Missouri Department of Economic Development Program Year 2024 Criteria – Suspension and debarment (2 CFR 180) Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended, debarred, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Condition – The Cooperative was unable to provide evidence that vendors used in covered transactions were not suspended, debarred, or otherwise excluded. Cause – The Cooperative’s policies and procedures were not adequate to ensure compliance with suspension and debarment requirements under the Uniform Guidance. Effect or Potential Effect – The Cooperative may enter into covered transactions with vendors who have become suspended, debarred, or otherwise excluded. Questioned Costs – None Context – The Cooperative was unable to provide evidence covered transactions were not with vendors suspended, debarred, or otherwise excluded. Recommendation – We recommend management design and implement internal controls to verify prior to entering into covered transaction that potential vendors are not suspension, debarment or otherwise excluded. Management's Response – Management acknowledges the audit finding related to suspension and debarment compliance under the Missouri ARPA Broadband Infrastructure Grant Program. Management is committed to implementing corrective measures to address the identified deficiencies and ensure full compliance with 31 CFR 19 subpart C.

Corrective Action Plan

Corrective Action Plan Assistance Listing Number 21.029 COVID-19 Coronavirus Capital Projects Fund U.S. Department of the Treasury Missouri Department of Economic Development Program Year 2024 Finding #2024-002 – Statement of Condition: The Cooperative was unable to provide evidence that vendors used in covered transactions were not suspended, debarred, or otherwise excluded. Response: Due to the current year finding, management set a goal to ensure the Missouri ARPA Broadband Infrastructure Grant Program guidelines related to debarred or suspended vendors are being met. To meet these guidelines management has compared the current vendor list to Excluded Parties List System found on SAM.GOV and found none of the currently used vendors on the list. Management has added this verification step to its new vendor process and will conduct annual self-assessment to ensure vendor eligibility documentation is current and up to date. The completion date for the above-mentioned corrective action was February 10, 2026.

Categories

Procurement, Suspension & Debarment Subrecipient Monitoring Eligibility

Programs in Audit

ALN Program Name Expenditures
21.029 COVID-19 CORONAVIRUS CAPITAL PROJECTS FUND $20.89M
97.036 DISASTER GRANTS - PUBLIC ASSISTANCE (PRESIDENTIALLY DECLARED DISASTERS) $712,574