Finding 25074 (2022-001)

Finding 2022-001 - Procurement and Suspension, and Debarment - Internal Control over Verification Against the System for Award Management (?SAM?) Assistance Listing Program Title and Number- Coronavirus State and Local Fiscal Recovery Funds 21.027 Federal Agency- Department of Treasury Pass-through Entity- N/A Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (Uniform Guidance) requires compliance with provisions of procurement, suspension, and debarment. Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the nonfederal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: During our audit, we noted that the City did not have documentation to support that it verified vendors selected for testing against the SAM to ensure that they were not suspended or debarred from federally? funded purchases. Cause: While the City has a formal policy requiring the purchasing department to perform verification of suspension or debarment over vendors that the City makes contracts with federally-funded projects, it does not maintain formal documentation that this procedure occurred. Effect: Without documented evidence of verifying whether the City was followings its policy, the City could not provide evidence of this control was being completed for federally-funded projects. There were no standard forms or templates that were used to document verification that parties are not suspended or debarred. Questioned Cost: None Context: See condition above for context for the finding. There was no documentation available for 13 out of 13 selections tested. However, none of the vendors selected for testing were suspended or debarred. Repeating Finding: No Recommendation: We recommend that the City implement a policy to formally document the procedures they are performing. Views of responsible officials of the auditee: The City agrees with the finding and the recommendation.