Finding 37884 (2022-004)

Significant Deficiency
Requirement
I
Questioned Costs
-
Year
2022
Accepted
2023-09-28
Audit: 32669
Organization: County of Champaign, Illinois (IL)

AI Summary

  • Core Issue: Nonfederal entities must ensure that lower-tier entities are not suspended or debarred before entering into transactions.
  • Impacted Requirements: Compliance with Uniform Grant Guidance and 2 CFR section 180.995 is mandatory.
  • Recommended Follow-Up: Implement a verification process to check the status of lower-tier entities before transactions.

Finding Text

Uniform Grant Guidance requires 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.

Corrective Action Plan

The County disagrees with regard to the inclusion of this assessment in the schedule of findings. The County adheres to the provisions outlined in 2 CFR section 180.995, which imposes a comprehensive verification process to ascertain that vendors are not under suspension or debarment prior to engaging in any contractual agreements. Federal guidance does not mandate the retention of documentation as evidence of the review conducted on SAM.gov's exclusions. Furthermore, in compliance with periodic federal reporting requirements, the County is obligated to report all transactions with vendors that exceed the threshold of $25,000. In this reporting, the County is obliged to furnish the vendors' business information, along with their Unique Entity Identifier (UEI). It is important to emphasize that any reimbursement requests as part of this reporting are reduced by any payments made to vendors who are suspended or disbarred. In light of the foregoing, the Auditor's Office recommends each department designate a staff member tasked with the responsibility of conducting the initial suspension and debarment verification for any vendor considered for procurement or agreements exceeding the aforementioned threshold. The results of this verification should be documented, and a screenshot or excerpt of the search should be securely stored in cloud support. The Auditor's Office will perform a thorough review of these records during the audit of requisitions or invoices.

Categories

Procurement, Suspension & Debarment Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 614326 2022-004
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
21.027 Coronavirus State and Local Fiscal Recovery Funds $6.46M
93.600 Head Start $487,894
93.569 Community Services Block Grant $447,912
93.568 Low-Income Home Energy Assistance $302,521
10.558 Child and Adult Care Food Program $290,734
14.231 Emergency Solutions Grant Program $282,351
17.259 Wia Youth Activities $252,584
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $248,997
17.258 Wia Adult Program $237,678
20.509 Formula Grants for Rural Areas and Tribal Transit Program $208,951
14.267 Continuum of Care Program $154,675
93.268 Immunization Cooperative Agreements $150,873
93.354 Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response $96,790
21.023 Emergency Rental Assistance Program $95,468
20.205 Highway Planning and Construction $94,274
97.042 Emergency Management Performance Grants $68,724
81.042 Weatherization Assistance for Low-Income Persons $55,445
97.024 Emergency Food and Shelter National Board Program $41,755
16.606 State Criminal Alien Assistance Program $40,435
10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program $35,664
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $30,889
93.558 Temporary Assistance for Needy Families $24,328
16.034 Coronavirus Emergency Supplemental Funding Program $23,728
10.555 National School Lunch Program $22,701
17.285 Apprenticeship USA Grants $21,787
14.239 Home Investment Partnerships Program $21,631
16.575 Crime Victim Assistance $20,808
93.069 Public Health Emergency Preparedness $18,808
90.401 Help America Vote Act Requirements Payments $14,726
10.553 School Breakfast Program $11,437
16.734 Special Data Collections and Statistical Studies $10,140
14.218 Community Development Block Grants/entitlement Grants $8,912
20.703 Interagency Hazardous Materials Public Sector Training and Planning Grants $4,583
17.278 Wia Dislocated Worker Formula Grants $3,810
93.563 Child Support Enforcement $2,839
66.605 Performance Partnership Grants $588