Finding Text
Information on the Federal Program: Assistance Listing Number 21.027?American Rescue Plan Act (ARPA) Coronavirus State and Local Fiscal Recovery Funds, U.S. Department of the Treasury. Pass-Through Entities and Award Numbers: Minnesota Department of Agriculture, award numbers 207317 and 207957; Minnesota Department of Human Services, award number 208490. Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Significant deficiency in internal control over compliance. Criteria: 2 CFR 200.303 of Subpart D, "Post Federal Award Requirements Standards for Financial and Program Management," of the Uniform Guidance requires a nonfederal entity to establish and maintain effective internal control over the federal award that provides reasonable assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award, including Procurement and Suspension and Debarment. Condition: There was not a policy in place to require checking whether vendors paid with grant funds were suspended or debarred. Cause: While the organization regularly purchases food and contracts with vendors to prepare meals, these purchases had not formerly been federally funded and all requirements of the new grant agreement had not been scrutinized to ensure controls related to suspension and debarment were in place. Effect or Potential Effect: A vendor paid with federal funds could have been suspended or debarred. Questioned Costs: None Context: No policy or process to check vendors against the suspension and debarment lists was identified. Repeat Finding: No Recommendation: We recommend the organization create a policy to check vendors against suspension and debarment lists and perform checks prior to initial purchasing and on a regular basis. Views of Responsible Officials: Agree and controls have now been implemented.