Finding 21864 (2022-001)

Material Weakness
Requirement
I
Questioned Costs
-
Year
2022
Accepted
2023-09-25
Audit: 19471
Organization: Knox County (IN)

AI Summary

  • Core Issue: The County failed to verify that vendors in covered transactions were not suspended or debarred, risking improper federal fund disbursement.
  • Impacted Requirements: Compliance with 2 CFR § 180.305 and 2 CFR § 180.200, which mandate verification of vendor eligibility for federal transactions.
  • Recommended Follow-Up: Implement internal controls to ensure verification of vendor status through SAM exclusions or certifications before contracting for federal-funded services.

Finding Text

2 CFR ? 180.305 states that Non-Federal entities are prohibited from entering into a covered transaction with parties that are suspended or debarred or whose principals are suspended or debarred, unless the Federal agency responsible for the transaction grants an exception under 2 CFR ? 180.135. 2 CFR ? 180.200 identifies ?covered transactions? as nonprocurement or procurement transactions at the primary tier, between a Federal agency and a person; or at the lower tier, between a participant in a covered transaction and another person. Procurement contracts for goods and services awarded under a nonprocurement transaction (e.g., grant or cooperative agreement) are covered transactions if the contracts are expected to equal or exceed $25,000 or meet certain other specified criteria outlined in 2 CFR ? 180.220. All nonprocurement transactions (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless exempt by 2 CFR ? 180.215. When a non-Federal entity enters into a covered transaction, the non-Federal entity must verify that the entity is not suspended or debarred or otherwise excluded. This verification may be accomplished by checking SAM exclusions (https://sam.gov ); collecting a certification from the entity, or adding a clause or condition to the covered transactions with that entity. The County did not have the proper internal controls in place to verify that all entities, with whom the County had entered into covered transactions, had not been suspended or debarred. During testing of nonpayroll disbursements for the AL #21.027 ARPA Coronavirus State and Local Fiscal Recovery Fund, we noted five instances out of seven tested in which the program had a payment to a vendor of more than $25,000 and there was no evidence the County checked the SAM exclusions, collected a certification from the entity, or added a clause or condition to the covered transaction with the vendor. Due to the deficient internal control structure, the required verification was not completed for the covered transaction in the AL #21.027 ARPA Coronavirus State and Local Fiscal Recovery Fund during the fiscal year ended December 31, 2022. Failing to have the appropriate controls in place may result in vendors receiving federal funds that are suspended or debarred. Prior to contracting with vendors that will be paid with federal funds, the County should verify the vendor is not suspended or debarred by checking the SAM exclusions, collecting a certification from the vendor, or adding a clause or condition to the covered transaction with the vendor.

Corrective Action Plan

Auditor shall review that a certification from the vendor is enclosed with expenditures. The Auditor had a discussion with Jason Booth and going forward that the certification will be completed by the vendors for transactions over $25,000 using ARPA funds.

Categories

Procurement, Suspension & Debarment Subrecipient Monitoring

Other Findings in this Audit

  • 598306 2022-001
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
21.027 Coronavirus State and Local Fiscal Recovery Funds $5.44M
93.658 Foster Care_title IV-E $1.98M
20.205 Highway Planning and Construction $1.08M
20.509 Formula Grants for Rural Areas and Tribal Transit Program $1.01M
93.558 Temporary Assistance for Needy Families $955,534
93.563 Child Support Enforcement $677,533
93.778 Medical Assistance Program $429,768
14.228 Community Development Block Grants/state's Program and Non-Entitlement Grants in Hawaii $337,513
93.767 Children's Health Insurance Program $333,538
10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program $314,111
17.259 Wia Youth Activities $248,754
93.659 Adoption Assistance $235,607
17.258 Wia Adult Program $194,604
20.106 Airport Improvement Program $124,513
97.042 Emergency Management Performance Grants $79,097
93.575 Child Care and Development Block Grant $67,748
20.513 Enhanced Mobility of Seniors and Individuals with Disabilities $63,065
17.278 Wia Dislocated Worker Formula Grants $59,703
93.556 Promoting Safe and Stable Families $50,221
21.032 Local Assistance and Tribal Consistency Fund $50,000
17.225 Unemployment Insurance $43,728
93.667 Social Services Block Grant $42,068
16.575 Crime Victim Assistance $36,842
93.747 Elder Abuse Prevention Interventions Program $35,819
17.207 Employment Service/wagner-Peyser Funded Activities $34,364
17.277 Workforce Investment Act (wia) National Emergency Grants $29,703
93.674 John H. Chafee Foster Care Program for Successful Transition to Adulthood $24,019
17.245 Trade Adjustment Assistance $5,374
90.404 2018 Hava Election Security Grants $4,717
93.645 Stephanie Tubbs Jones Child Welfare Services Program $1,465