Finding Text
Criteria or specific requirement: 2 CFR §180.300 and 2 CFR §200.332 require pass-through entities to ensure that subrecipients are not suspended or debarred from participating in federal programs. This may be accomplished by checking SAM.gov, obtaining a certification from the subrecipient, or including appropriate certifications in the subaward agreement. The pass-through entity should maintain documentation evidencing performance of the control. Condition: During testing of subrecipient monitoring controls for the JAG program, we noted the County did not maintain documentation demonstrating it verified the suspension and debarment status of subrecipients prior to issuing federal awards. Specifically, for the subrecipient selected for testing, management was unable to provide evidence that a SAM.gov search was performed or that a suspension and debarment certification was obtained and retained. Question costs: None Context: This finding applies to all three subrecipients that received pass-through funds during the fiscal year. Cause: County personnel were not retaining evidence that suspension and debarment verification procedures had been completed for subrecipients receiving federal awards. Effect: CLA recommends the County implement procedures requiring personnel to perform and retain documentation of suspension and debarment verification for all subrecipients prior to issuing subawards. Documentation may include SAM.gov search results, written certifications from subrecipients, or certifications incorporated into the subaward agreement. Repeat Finding: No Recommendation: CLA recommends the County implement procedures requiring personnel to perform and retain documentation of suspension and debarment verification for all subrecipients prior to issuing subawards. Documentation may include SAM.gov search results, written certifications from subrecipients, or certifications incorporated into the subaward agreement. Views of Responsible Officials: Management does not disagree with the finding.