Finding Text
Reference # and title: 2022-004 Suspension and Debarment
Federal Grantor/Program Name Assistance Listing No. Award Year
United States Department of Treasury
Coronavirus State and Local Fiscal Recovery Funds 21.027 2022
Criteria or specific requirement: Non-Federal entities are prohibited from contracting with or making subawards
under covered transactions to parties that are suspended or debarred. 'Covered transactions' include contracts for
goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are
expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. When a
non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal 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. This verification may be accomplished by (1) checking the
System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA), (2)
collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that
entity (2 CFR section 180.300).
Condition found: In testing compliance and internal controls with respect to the Uniform Guidance 2 CFR section
180.300, the Police Jury did not properly verify that the vendor was not excluded or debarred before contracting with
the vendor. Additionally, no such clause or representation was included in the signed contract or purchase order
certifying that the vendor was not suspended, debarred, or otherwise excluded from participating in the covered
transaction. Our audit procedures did not identify any covered transactions that equaled or exceeded $25,000 with
vendors suspended, debarred, or otherwise excluded from providing services under the program.
Context: The Police Jury did not verify covered transactions with SAM, collect a certification from the entity, or
add a clause or condition to covered transactions exceeding $25,000.
Possible asserted effect (cause and effect):
Cause: The Police Jury does not have policy and procedures requiring verification or certification that the
vendor in which it expects to expend $25,000 or more has not been suspended, debarred, or otherwise excluded
from participating in the transaction.
Effect: Without vendor verification or certification, the Police Jury may potentially enter into
contracts/transactions with suspended, debarred, or otherwise excluded vendors.
Recommendation to prevent future occurrences: The Police Jury should implement policies and procedures
requiring verification or certification that a vendor, with which it plans to expend $25,000 or more has not been
suspended, debarred, or otherwise excluded from participating in the transaction by adding a clause or condition to
all contracts or purchase orders.
Origination date and prior year reference (if applicable): This finding originated in the fiscal year ended
December 31, 2021.
View of responsible official: I concur with the recommendation.