Finding 1236662 (2025-001)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2025
Accepted
2026-09-25
Audit: 412204
Organization: Mid-America Regional Council (MO)
Auditor: RUBINBROWN LLP

AI Summary

  • Core Issue: A contract was executed without verifying if the vendor was suspended or debarred, violating federal regulations.
  • Impacted Requirements: Compliance with 2 CFR Part 180 and 2 CFR Part 1200, which mandate checks against SAM.gov or similar methods before entering contracts.
  • Recommended Follow-Up: Implement procedures to ensure suspension and debarment verification is documented for all contracts, retaining evidence in procurement files.

Finding Text

Finding 2025-001 – Suspension and Debarment – Compliance and Control Finding, Significant Deficiency Federal Award. No. 20.505 Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research Federal Agency: U.S. Department of Transportation Pass-Through Entity: Kansas Department of Transportation; Missouri Department of Transportation Criteria Or Specific Requirement: 2 CFR Part 180 and 2 CFR Part 1200 prohibit non-Federal entities from entering into covered transactions with parties that are suspended or debarred from participation in Federal programs. The Compliance Supplement requires the auditee to verify that vendors receiving covered contracts are not suspended or debarred through review of SAM.gov, obtaining a certification from the vendor, or including appropriate suspension and debarment language in the contract. Condition: During testing of covered vendor contracts, we identified one contract for which the auditee did not perform or document a suspension and debarment verification prior to executing the contract. No evidence was maintained demonstrating that the vendor's status was checked through SAM.gov or another allowable method before entering into the agreement. Cause: Management did not have procedures in place to ensure suspension and debarment verification was completed and documented prior to contract execution for all covered transactions. Effect: The auditee is at risk of entering into agreements with vendors that are suspended or debarred from participation in Federal programs, that could result in noncompliance with Federal requirements and the potential disallowance of related expenditures. Questioned Costs: None. A subsequent review determined the vendor was not listed as suspended or debarred in SAM.gov; therefore, no questioned costs were identified. Context: Of the covered vendor contracts tested for suspension and debarment compliance, one of four contracts tested did not contain documentation demonstrating that a suspension and debarment verification was performed prior to contract execution. Identification As A Repeat Finding: Not a repeat finding. Recommendation: We recommend management establish and implement procedures requiring personnel to verify and document suspension and debarment status prior to entering into all covered contracts. Verification should be retained in the procurement file and may include a SAM.gov search, vendor certification, or other method permitted by Federal regulations. Views Of Responsible Officials: Management agrees with the finding and recommendation. Procedures will be updated to require documented suspension and debarment verification prior to contract execution for all covered transactions. Anticipated Completion Date: August 31, 2026 Contact Person: Darlene Pickett, Accountant

Corrective Action Plan

Section II – Financial Statement Findings: Finding 2025-001 – Significant Deficiency Description of Finding: During the course of audit testing, it was noted that one contract did not contain documentation evidencing verification of the vendor’s suspension and debarment status prior to execution of the contract. Views of Responsible Officials: MARC acknowledges and concurs with the finding as presented. Planned Corrective Action: In September 2026, MARC enhanced its automated forms and control procedures to require timely verification and documentation of suspension and debarment status prior to contract execution for all covered transactions. These enhanced procedures are intended to ensure consistent compliance with applicable procurement requirements going forward. Person Responsible for Corrective Action: Erika Benitez, Director of Finance Anticipated Completion Date: September 2026

Categories

Procurement, Suspension & Debarment

Programs in Audit

ALN Program Name Expenditures
93.600 HEAD START $4.77M
20.505 METROPOLITAN TRANSPORTATION PLANNING AND STATE AND NON-METROPOLITAN PLANNING AND RESEARCH $3.14M
20.933 NATIONAL INFRASTRUCTURE INVESTMENTS $1.65M
93.243 SUBSTANCE ABUSE AND MENTAL HEALTH SERVICES PROJECTS OF REGIONAL AND NATIONAL SIGNIFICANCE $895,148
20.205 HIGHWAY PLANNING AND CONSTRUCTION $784,194
16.753 CONGRESSIONALLY RECOMMENDED AWARDS $477,081
81.086 CONSERVATION RESEARCH AND DEVELOPMENT $361,355
66.046 CLIMATE POLLUTION REDUCTION GRANTS $321,545
20.939 SAFE STREETS AND ROADS FOR ALL $268,228
16.745 CRIMINAL AND JUVENILE JUSTICE AND MENTAL HEALTH COLLABORATION PROGRAM $249,056
93.667 SOCIAL SERVICES BLOCK GRANT $207,533
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $187,532
93.889 NATIONAL BIOTERRORISM HOSPITAL PREPAREDNESS PROGRAM $141,006
97.067 HOMELAND SECURITY GRANT PROGRAM $134,890
10.331 FOOD INSECURITY NUTRITION INCENTIVE GRANTS PROGRAM $118,680
93.734 EMPOWERING OLDER ADULTS AND ADULTS WITH DISABILITIES THROUGH CHRONIC DISEASE SELF-MANAGEMENT EDUCATION PROGRAMS – FINANCED BY PREVENTION AND PUBLIC HEALTH FUNDS (PPHF) $115,155
93.045 SPECIAL PROGRAMS FOR THE AGING, TITLE III, PART C, NUTRITION SERVICES $109,263
93.043 SPECIAL PROGRAMS FOR THE AGING, TITLE III, PART D, DISEASE PREVENTION AND HEALTH PROMOTION SERVICES $97,220
66.818 BROWNFIELDS MULTIPURPOSE, ASSESSMENT, REVOLVING LOAN FUND, AND CLEANUP COOPERATIVE AGREEMENTS $92,100
93.575 CHILD CARE AND DEVELOPMENT BLOCK GRANT $86,103
11.302 ECONOMIC DEVELOPMENT_SUPPORT FOR PLANNING ORGANIZATIONS $80,806
20.941 STRENGTHENING MOBILITY AND REVOLUTIONIZING TRANSPORTATION (SMART) GRANTS PROGRAM $57,280
97.039 HAZARD MITIGATION GRANT $52,643
66.001 AIR POLLUTION CONTROL PROGRAM SUPPORT $52,000
20.513 ENHANCED MOBILITY OF SENIORS AND INDIVIDUALS WITH DISABILITIES $51,548
20.703 INTERAGENCY HAZARDOUS MATERIALS PUBLIC SECTOR TRAINING AND PLANNING GRANTS $49,556
93.576 REFUGEE AND ENTRANT ASSISTANCE DISCRETIONARY GRANTS $41,778
93.495 COMMUNITY HEALTH WORKERS FOR PUBLIC HEALTH RESPONSE AND RESILIENT $40,029
66.445 INNOVATIVE WATER INFRASTRUCTURE WORKFORCE DEVELOPMENT PROGRAM (SDWA 1459E) $30,325
93.988 COOPERATIVE AGREEMENTS FOR DIABETES CONTROL PROGRAMS $24,445
81.117 ENERGY EFFICIENCY AND RENEWABLE ENERGY INFORMATION DISSEMINATION, OUTREACH, TRAINING AND TECHNICAL ANALYSIS/ASSISTANCE $24,108
66.460 NONPOINT SOURCE IMPLEMENTATION GRANTS $21,766
20.600 STATE AND COMMUNITY HIGHWAY SAFETY $19,971
66.306 ENVIRONMENTAL JUSTICE COLLABORATIVE PROBLEM-SOLVING COOPERATIVE AGREEMENT PROGRAM $19,014
66.605 PERFORMANCE PARTNERSHIP GRANTS $14,738
66.454 WATER QUALITY MANAGEMENT PLANNING $6,803
20.507 FEDERAL TRANSIT_FORMULA GRANTS $5,662
93.048 SPECIAL PROGRAMS FOR THE AGING, TITLE IV, AND TITLE II, DISCRETIONARY PROJECTS $3,780
93.042 SPECIAL PROGRAMS FOR THE AGING, TITLE VII, CHAPTER 2, LONG TERM CARE OMBUDSMAN SERVICES FOR OLDER INDIVIDUALS $2,867
93.052 NATIONAL FAMILY CAREGIVER SUPPORT, TITLE III, PART E $100
93.044 SPECIAL PROGRAMS FOR THE AGING TITLE III, PART B GRANTS FOR SUPPORTIVE SERVICES AND SENIOR CENTERS $23
93.044 SPECIAL PROGRAMS FOR THE AGING, TITLE III, PART B, GRANTS FOR SUPPORTIVE SERVICES AND SENIOR CENTERS $-21,045
93.053 NUTRITION SERVICES INCENTIVE PROGRAM $-30,504