Finding 28757 (2022-002)

Suspension and Debarment U.S. Department of Transportation U.S. Department of Treasury U.S. Department of Health and Human Services Highway Planning and Construction Cluster COVID-19 Coronavirus State and Local Fiscal Recovery Effort Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) 20.205 21.027 93.323 Various Various Various None Material Weakness in Internal Control over Compliance, Other Matters Some federal programs are subject to suspension and debarment requirements, which are designed to ensure that federal funds are not awarded to individuals or entities that have a history of noncompliance with federal regulations or that pose a risk to the integrity of federal programs. The suspension and debarment regulations require recipients of federal funding to ensure contractors and subrecipients are not suspended or debarred by the federal government prior to executing a contract. The County did not have a process or internal controls designed to ensure compliance with the Suspension & Debarment requirements. Procurement was direct and material to the Highway Planning and Construction Cluster, Coronavirus State and Local Fiscal Recovery Effort, Epidemiology and Laboratory Capacity for Infectious Diseases (ELC). As a result, a total of 49 contracts were subject to the suspension and debarment requirements. The County did not perform the suspension and debarment procedures for any of the contracts subject to the suspension and debarment requirements. The County has not designed and implemented internal controls to ensure compliance with suspension and debarment requirements outlined in 2 CFR sections 416.1(a), 416.1(b) and 417.215(a)(1) and in 7 CFR section 210.21(g), 215.14a(e), 220.16(f), and 225.17(e). Federal funding could be spent on organizations that are suspended or disbarred. We recommend the County implement internal control to ensure that suspension and debarment assessment are performed during the procurement and contracting phase. In addition, sufficient documentation should be retained to evidence suspension and debarment is performed. No There is no disagreement with the audit finding.