Finding Text
Reference Number: 2023-001
Prior Year Finding: No
Federal Agency:
Pass-Through Agency: U.S. Department of Homeland Security
Government of the District of Columbia Homeland Security and Emergency Management Agency
Federal Program: Securing the Cities Program
Assistance Listing Number: 97.106
Award Number and Year: 17STC117-02, 20STC117-01 (9/1/2021-8/31/2023)
Compliance Requirement: Suspension and Debarment
Type of Finding: Significant Deficiency in Internal Control Over Compliance
Criteria or specific requirement:
Compliance: 2 CFR 200.214 Suspension and Debarment restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
2 CFR 180.300 states that an entity may determine suspension and debarment status by:
(a) Checking SAM (System for Award Management) Exclusions; or
(b) Collecting a certification from that person; or
(c) Adding a clause or condition to the covered transaction with that person.
Control: Per 2 CFR section 200.303(a), a non-Federal entity must: 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 comply 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:
MWCOG did not determine the suspension and debarment status of vendors with expenditures exceeding $25,000 as required by federal regulations.
Context:
The suspension and debarment status for 2 of 2 vendors was not documented.
Questioned costs:
There are no questioned costs related to this finding as the vendors were not federally suspended or debarred.
Cause:
MWCOG’s internal controls over suspension and debarment are not sufficient to ensure that all vendors’ suspension and debarment status is documented.
Effect:
Failure to verify and document the suspension and debarment status of vendors may result in MWCOG issuing payments to vendors that are suspended or debarred and not authorized to provide services under the program.
Recommendation:
MWCOG should ensure policies and procedures include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors.
Views of responsible officials:
MWCOG will ensure that all vendors’ suspension and debarment status be documented in the procurement files at the time of contract with the vendors.