Finding 31179 (2022-001)

Significant Deficiency

Requirement

Questioned Costs

Year

2022

Accepted

2023-06-12

Audit: 30412

Organization: Tacoma-Pierce County Chamber of Commerce (WA)

Auditor: Johnson Stone & Pagano PC Johnson Stone & Pagano

AI Summary

Core Issue: Lack of a policy to check if vendors are suspended or debarred before procurement.
Impacted Requirements: Non-compliance with OMB guidance on vendor eligibility for federal contracts.
Recommended Follow-Up: Implement contract provisions on suspension/debarment, train staff on procurement requirements, and establish vendor verification procedures.

Finding Text

2022-001 Procurement, Suspension and Debarment Federal Program Information Funding Agency: U.S. Department of the Treasury Federal ALN: 21.027 Criteria Per OMB guidance, non-federal entities are prohibited from contracting with parties that are suspended or debarred, or whose principals are suspended or debarred. The guidance also requires the entities to follow documented procurement procedures. Condition There is no policy in place for procurement procedures to determine whether vendors are suspended or debarred. Context Per our review of vendors over the applicable threshold, there was no documentation of having been reviewed for procurement, suspension or debarment. Cause Staff were not aware of the specific compliance requirements and procedures for procurement, suspension and debarment status. Effect Purchases may occur that do not follow the policy, and contracts to vendors that had been suspended or debarred could be awarded and not detected. Auditor's Recommendations Tacoma-Pierce County Chamber of Commerce should include a provision in contracts with respect to suspension and debarment, communicate all requirements for procurement to staff and establish procedures to verify vendors are not suspended or debarred.

Corrective Action Plan

Finding One: 2022-001 Procurement, Suspension and Debarment Auditor?s Recommendations: The Organization should adopt Procurement Policy including a section concerning Federal Awards which will include a section regarding the verification of the status of each potential vendor before disbursement of Federal funds. CEO, Andrea Reay, will review and approve this policy and the Tacoma-Pierce County Chamber of Commerce (the ?Chamber?) Board of Directors will approve this policy. Response: CEO, Andrea Reay, will update the Chamber?s policies with a Procurement Policy, including a section concerning Federal Awards. Vendors will be verified before disbursement of Federal funds. The new PP will include the following language. The Chamber employees who authorize the use of Federal funds will: -Read and sign a document stating that they are aware of the Federal provisions requiring concerning Suspension and Debarment -Confirm with the CEO, or appropriate delegee that the vendor has been checked prior to fund distribution using the SAM.gov registration. CEO, or appropriate delegee, will develop a process for checking vendor debarment status and include language outlining the process in the procurement policy. CEO, or appropriate delegee, will be responsible for verifying that all vendors being paid using Federal funds, will have been checked for debarment prior to disbursing future Federal funding. Timing of remediation completion: CEO, Andrea Reay, will complete by March 1, 2023.

Other Findings in this Audit

31180 2022-001

Significant Deficiency
607621 2022-001

Significant Deficiency
607622 2022-001

Significant Deficiency

Programs in Audit

ALN	Program Name	Expenditures
14.228	Community Development Block Grants/state's Program and Non-Entitlement Grants in Hawaii	$165,597
21.027	Coronavirus State and Local Fiscal Recovery Funds	$121,073