Finding Text
2022-002: Written Debarred, Suspended Vendors & Federal Standards of Conflict Finding Prior Year Findings: None Department Agency: Environmental Protection Agency State Department: Wyoming State Loan & Investment Board Office of State Lands & Investments Assistance Listing Number: ALN#66.468 & ALN #66.458 Compliance Area: Procurement & Suspension & Debarment (I) Type of Finding: Significant Deficiency Questioned Costs: None Criteria: The Town of Lusk should have written standards of conduct in place to verify any entity (vendor) with which the County spends Federal expenditures or conducts business transactions be not debarred, suspended, or otherwise excluded per 2 CFR 200.318(h) and 2 CFR 180. The written standard should address conduct covering conflicts of interest governing the performance of its employees and contractors engaged in the selection, award, and administration of contracts (Uniform Guidance Section 200.318c and 45 CFR sections 52.203-13 and 52.203-16). Condition: The Town of Lusk did not have written controls in place to ensure that vendors were not suspended or debarred or included on the list of vendors prior to entering into a contract with the Town. The written standard of conduct covering conflicts of interest and governing the performance of its employees and contractors engaged in the selection, award and administration of Federal grant contracts. Cause and Effect: The Town of Lusk due to large influx of Federal expenditures for the Drinking Water SRF and the Clean Water SRF projects. There was not a control in place to ensure that vendors or contractors the Town entered into contracts with were not suspended or debarred before contracts were executed. Without a reliable control in place to ensure compliance, the Town of Lusk could enter into a contract with a suspended or debarred party and have a conflict of interest with the Federal written contracted parties. Repeat Finding: No Recommendation: We recommend that the Town of Lusk put written internal controls in place such as using a checklist to ensure Federal funds that pay contractors are not suspended or debarred and should consider The Town of Lusk adopt a policy on procurement for debarment. The town needs to adopt a written policy when spending Federal funds, to ensure no conflict of interests exist. Response: Please see the last page of this report for the Town's response to this finding.