Finding 36354 (2022-001)

Significant Deficiency
Requirement
I
Questioned Costs
-
Year
2022
Accepted
2023-03-29
Audit: 28400
Organization: City of San Buenaventura (CA)

AI Summary

  • Core Issue: The City failed to provide proof that it checked if a vendor was suspended or debarred before making a transaction.
  • Impacted Requirements: Compliance with 2 CFR Part 200, which mandates internal controls for suspension and debarment verification.
  • Recommended Follow-Up: The City should establish procedures to keep verification documentation to support compliance with internal controls.

Finding Text

Criteria or Specific Requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of suspension and debarment. The City should have internal controls designed to ensure compliance with those provisions. Condition: The City was not able to provide supporting documentation that the City verified the vendor was not suspended or debarred prior to entering the transaction. Questioned Costs: None. Context: There was only one vendor during FY 21-22 that was a covered transaction for this program. Cause: The City did not maintain supporting documentation that the verification of suspension or debarment was performed prior to entering into the contract. Effect: The auditor noted no instances of noncompliance with the provisions of suspension, and debarment; however, we were not able to verify that the City followed their internal controls to ensure the vendor was not suspended or debarred prior to entering the transaction. Repeat Finding: This is not a repeat finding. Recommendation: We recommend the City implement procedures to ensure that verification documentation for suspension and debarment is maintained to support the City's internal control over compliance. View of Responsible Officials: There is no disagreement with the audit finding.

Corrective Action Plan

Department of Transportation 2022-001 Highway Planning and Construction Cluster? Assistance Listing No. 20.205 Recommendation: We recommend the City implement procedures to ensure that verification documentation for suspension and debarment is maintained to support the City's internal control over compliance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The City?s Procurement Manual requires all vendors to comply with the Code of Federal Regulations (CFR), specifically 2 CFR Part 200 when the expenditure of Federal funds is anticipated, whether a grant, cooperative agreement or reimbursement of disaster expenses. While the City makes great effort to ensure that vendors are in good standing with the federal government and are not suspended or debarred prior to engaging their services, the City agrees that additional procedures are necessary to better document the verification. Therefore, the City will implement the following procedures when the expenditure of Federal funds is anticipated: ? The City will require project managers (during the bidding process) to verify that all responsible vendors are in good standing with the federal government and are not suspended or debarred. The City will also require that the project managers include documentation of such verification for vendors to be advanced to the next level of the procurement process. Additionally, documentation of the verification of the selected bidder shall be filed and forwarded to the Grant Accountant for their files. ? The Grant Accountant will confirm receipt of verification noted above for each vendor charged to federal grants. If such verification has not been received, they will reach out to the responsible department to obtain such verification. Name(s) of the contact person(s) responsible for corrective action: Jason Williams, Accounting Manager Planned completion date for corrective action plan: 06/30/2023

Categories

Procurement, Suspension & Debarment Allowable Costs / Cost Principles

Other Findings in this Audit

  • 612796 2022-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
14.239 Home Investment Partnerships Program $676,022
14.218 Community Development Block Grants/entitlement Grants $477,918
15.504 Title Xvi Water Reclamation and Reuse Program $465,366
21.027 Coronavirus State and Local Fiscal Recovery Funds $431,623
20.205 Highway Planning and Construction $190,203
97.067 Homeland Security Grant Program $109,068
20.600 State and Community Highway Safety $100,281
20.608 Minimum Penalties for Repeat Offenders for Driving While Intoxicated $97,802
93.045 Special Programs for the Aging_title Iii, Part C_nutrition Services $70,512
97.012 Boating Safety Financial Assistance $36,877
16.738 Edward Byrne Memorial Justice Assistance Grant Program $36,001
10.558 Child and Adult Care Food Program $8,266
97.044 Assistance to Firefighters Grant $6,360