Finding 1240420 (2025-001)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2025
Accepted
2026-10-14
Audit: 414923
Organization: City of Stuart (FL)

AI Summary

  • Core Issue: The auditee failed to document vendor suspension and debarment checks before awarding contracts, violating federal compliance requirements.
  • Impacted Requirements: Non-federal entities must verify vendor eligibility through SAM.gov or other methods and retain documentation to prove compliance.
  • Recommended Follow-up: Revise procurement policies to mandate documentation retention for vendor checks and implement monitoring controls to ensure compliance before contract awards.

Finding Text

Federal Program: Coronavirus State and Local Fiscal Recovery Funds COVID-19 Award Listing Number: 21.027 Federal Agency: Department of Treasury Compliance Requirement: Procurement, Suspension and Debarment Type of Finding: Material Weakness in Internal Control Over Compliance Questioned Costs: None identified Criteria In accordance with 2 CFR §§ 180.300, 180.320, and 200.214, non-federal entities may not enter into covered transactions with parties that are suspended or debarred from participating in federal programs. Prior to awarding a covered contract, recipients and subrecipients must verify that the vendor is not suspended or debarred by reviewing SAM.gov, obtaining a certification from the vendor, or including an appropriate clause in the contract. Documentation supporting the verification performed should be retained to demonstrate compliance with federal requirements. Condition During testing of procurement transactions charged to the Coronavirus State and Local Fiscal Recovery Funds program, the auditee was unable to provide documentation demonstrating that suspension and debarment verification procedures were performed prior to contract award. Management indicated that staff routinely verified vendor eligibility through SAM.gov; however, evidence of the searches was not retained in the procurement files. As part of audit procedures, the auditors subsequently performed SAM.gov searches for the vendors tested and noted that none were suspended or debarred. Context Four (4) of four (4) covered transactions tested did not contain documentation supporting the completion of suspension and debarment verification procedures. The sample was not and was not intended to be, a statistically valid sample. Cause The auditee's procurement policies and procedures were not followed, which required documentation supporting suspension and debarment verification activities. In addition, management's review controls were not designed to ensure that evidence of compliance was maintained within the procurement file. Effect The lack of retained documentation increases the risk that contracts funded with federal awards could be awarded to suspended or debarred vendors and prevents the auditee from demonstrating compliance with Uniform Guidance procurement requirements. Federal procurement guidance emphasizes verifying vendor eligibility through SAM.gov or other allowable methods. Identification as a repeat finding Not a repeat finding Recommendation We recommend that management revise procurement policies and procedures to require the retention of documentation supporting suspension and debarment verification for all covered transactions, including: • Vendor name searched • Date of search • Search results • Evidence of review and approval Management should also implement a monitoring control to ensure required documentation is maintained before contract award and retained in the procurement file. Views of Responsible Officials See Corrective Action Plan letter.

Corrective Action Plan

Finding 2025-001 Federal Program: Coronavirus State and Local Fiscal Recovery Funds COVID-19 (ALN 21.027) Contact Person Responsible for Corrective Action: Financial Services Director Corrective Action Planned: The City will revise procurement procedures to require retention of documentation supporting SAM.gov suspension and debarment verification for all covered transactions. A standardized procurement checklist will be implemented and reviewed by supervisory personnel prior to contract execution. Procurement staff will receive training on federal procurement requirements and documentation retention procedures. Anticipated Completion Date: September 30, 2027 Management Response: The City concurs with the finding and will implement the corrective actions described above.

Categories

Procurement, Suspension & Debarment Subrecipient Monitoring

Programs in Audit

ALN Program Name Expenditures
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $1.92M
14.228 COMMUNITY DEVELOPMENT BLOCK GRANTS/STATE'S PROGRAM AND NON-ENTITLEMENT GRANTS IN HAWAII $548,751
16.607 BULLETPROOF VEST PARTNERSHIP PROGRAM $3,090