Finding 2747 (2023-001)

Significant Deficiency
Requirement
I
Questioned Costs
-
Year
2023
Accepted
2023-11-30
Audit: 4742
Organization: Town of Oakland, MD (MD)

AI Summary

  • Core Issue: The Town did not verify suspension and debarment for vendors receiving over $25,000 in federal grant funds.
  • Impacted Requirements: This violates 2 CFR 200.303, which mandates effective internal controls to ensure compliance with federal regulations.
  • Recommended Follow-Up: Implement new policies and procedures to ensure all vendors are checked against suspension and debarment lists.

Finding Text

Repeat Finding: No Program Name/Assistance Listing Title: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Agency: U.S. Department of Treasury Pass-Through Agency: N/A Federal Award Number: N/A Type of Finding: Significant Deficiency CRITERIA: 2 CFR 200.303 requires that a non-federal entity must “(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Non-Federal entities are prohibited from contracting with or making sub awards under covered transactions to parties that are suspended or debarred. “Covered transactions” include those procurement contracts for goods and services awarded under a non-procurement transaction that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR §180.220. CONDITION: Verification of suspension and debarment was not performed for all vendors with whom the Town spent at least $25,000 using federal grant monies. QUESTIONED COSTS: N/A CONTEXT: Payments exceeding $25,000 were made to 6 vendors totaling $768,885 for the fiscal year ended June 30, 2023. Total expenditures for the Coronavirus State and Local Fiscal Recovery Plan were $789,178 for the fiscal year ended June 30, 2023. CAUSE: The internal controls over the suspension and debarment were not adequately designed or implemented. EFFECT: Payments could be made to parties who are suspended or debarred and not be identified by management. RECOMMENDATION: Officials should implement policies and procedures which ensure compliance for parties subject to the suspension and debarment requirement. VIEWS OF RESPONSIBLE OFFICIALS: Management concurs with the finding and has developed a plan to correct the finding. See corrective action plan.

Corrective Action Plan

Correction Action to be Taken: Management will implement controls which ensure parties subject to this requirement are verified as not being present on the suspension and debarment list prior to initiating contracts or payments.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 579189 2023-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
21.027 Coronavirus State and Local Fiscal Recovery Funds $789,178
14.228 Community Development Block Grants/state's Program and Non-Entitlement Grants in Hawaii $616,842
10.766 Community Facilities Loans and Grants $1,066