Finding 34755 (2022-003)

2022-003 - Federal Grants Management - Procurement Policy Federal Agency: Department of Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Award Period: March 1, 2021 ? December 31, 2024 Type of Finding: Significant deficiency in internal control over compliance, other matters. Criteria or Specific Requirement: 2 CFR Section 200.214 requires non-federal entities to follow suspension and debarment regulations outlined in 2 CFR part 180. When a nonfederal entity enters into a covered transaction with an entity at a lower tier, the nonfederal 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. 2 CFR 200.303 states ?The 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 or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) Condition: The County did not perform a search for suspension and debarment for vendors the County initiated procurement transactions in excess of $25,000. Questioned Costs: None Context: There were five transactions that exceeded the $25,000 covered transaction threshold during the granting period. During our testing, it was noted on four of the five items tested that Florence County was not reviewing vendors prior to entering into a contract with a vendor to ensure the vendor was not on the suspended or debarred vendor list maintained by the General Services Administration. Cause: The County was not aware of the requirements under suspension and debarment. Effect: The County could contract with a vendor that has been suspended or debarred from receiving federal funds. Recommendation: We recommend the County use sam.gov or the ELPS listing to review clients at the beginning of the year or before a transaction is incurred in accordance with Uniform Guidance requirements. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.