Finding 1241764 (2024-005)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2024
Accepted
2026-11-06
Audit: 415766
Organization: Bristol Township (PA)

AI Summary

  • Core Issue: The Township failed to provide documentation proving that it checked for suspension and debarment status before entering into contracts.
  • Impacted Requirements: This finding violates compliance requirements under 2 CFR 200.214 and 2 CFR 180.300 regarding verification of contractor eligibility for federal awards.
  • Recommended Follow-Up: Management should update policies to include verification procedures and ensure documentation is retained, specifically evidence from SAM.gov with verification dates.

Finding Text

Prior Year Finding: No Federal Agency: U.S. Department of the Treasury Federal Program: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Award Number and Year: N/A Compliance Requirement: Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matter Condition: Of the 5 selected transactions for testing, the Township was unable to provide documentation demonstrating that suspension and debarment verification was performed prior to entering into the transaction. Criteria or specific requirement: Compliance: 2 CFR 200.214 Suspension and Debarment, restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in Federal awards. 2 CFR 180.300 states that an entity must determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person Control: Per 2 CFR section 200.303(a), a non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the entity is managing the award in compliance with Federal statutes, regulations, and the terms and conditions for the award. The internal controls should align with the Standards for Internal Control in the Federal Government or the Internal Control – Integrated Framework issued by COSO. Questioned costs: None Effect: The Township could not demonstrate compliance with the suspension and debarment requirements to verify whether the contractors were not excluded or disqualified prior to entering into the contract, however per review of SAM.gov, the contractors were not suspended or debarred. Cause: The Township did not have sufficiently documented internal controls to ensure compliance with federal suspension and debarment requirements for the retention of evidence showing the method or date of verification. Recommendation: We recommend that management review and update its policies and procedures to include suspension and debarment verification requirements and establish steps for retaining supporting documentation, such as evidence of verification obtained from SAM.gov, including the date of verification. Views of Responsible Officials: Management agrees with the finding.

Corrective Action Plan

U.S. Department of Treasury COVID-19-Coronavirus State and Local Fiscal Recovery Funds -Assistance Listing No. 21.027 Recommendation: We recommend that management review and update its policies and procedures to include suspension and debarment verification requirements and establish steps for retaining supporting documentation, such as evidence of verification obtained from SAM.gov, including the date of verification. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management has updated existing policies and procedures to establish formal suspension and debarment verification requirements for applicable contractors, vendors, subrecipients, and other covered entities in accordance with applicable federal requirements. Management has established procedures requiring verification of applicable parties against the federal System for Award Management (SAM.gov) exclusions database before entering into covered transactions and at other required intervals, as applicable. Management will provide training to appropriate procurement, finance, and grant administration personnel regarding suspension and debarment requirements, verification procedures, and supporting documentation retention. Management will conduct periodic reviews of covered transactions to verify that required suspension and debarment checks were completed and that supporting evidence is properly documented and retained . Document and address any exceptions identified. Name(s) of the contact person(s) responsible for corrective action: Township Manager, Finance Officer and Department Head Planned completion date for corrective action plan: Initial procedures andchecklists will be developed within 60 days.The revised controls will be fully applied during the next year-end close, subject to the applicable fiscal year-end schedule.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 1241763 2024-004
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $102,097
16.607 BULLETPROOF VEST PARTNERSHIP PROGRAM $13,018
14.218 COMMUNITY DEVELOPMENT BLOCK GRANTS/ENTITLEMENT GRANTS $7,450