Finding 384403 (2023-001)

Material Weakness
Requirement
I
Questioned Costs
-
Year
2023
Accepted
2024-03-26
Audit: 297558
Organization: City of Cheboygan (MI)

AI Summary

  • Core Issue: The City lacks proper internal controls to ensure contractors are not debarred or suspended from federal assistance programs.
  • Impacted Requirements: Non-compliance with Uniform Guidance §200.214 and 2 CFR part 180 regarding contractor eligibility.
  • Recommended Follow-Up: Implement a verification process for contractors against the SAM.gov database before awarding bids and retain documentation of this verification.

Finding Text

Procurement, Suspension, and Debarment Finding Type: Material Weakness in Internal Control over Compliance. Programs: United States Environmental Protection Agency Capitalization Grants for Clean Water State Revolving Funds (ALN #66.458) and Capitalization Grants for Drinking Water State Revolving Funds (ALN #66.468) Criteria: The Uniform Guidance, §200.214, requires that a recipient of federal awards are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict 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. Condition/Finding: During our audit procedures over the City’s debarment and suspension procedures, we noted that the City relies on their engineers to make sure contractors are not debarred, suspended, or otherwise excluded from Federal assistance programs or activities. The City does not have a process in place to verify the engineers are in fact monitoring the contractors on the project. Cause: The City does not have the proper internal controls in place to ensure that all contractors are not debarred, suspended, or otherwise excluded from Federal assistance programs or activities. Effect: The City did not follow requirements to check whether a vendor is suspended or debarred. Questioned Costs: No costs have been questioned as a result of this finding. Recommendation: We recommend that the City verify that any vendors or contractors selected are verified as neither suspended or debarred per the SAM.gov website prior to awarding the bid, and, that the City retain documentation of their verification in the bid file.

Categories

Procurement, Suspension & Debarment Subrecipient Monitoring

Other Findings in this Audit

  • 384401 2023-001
    Material Weakness
  • 384402 2023-002
    Material Weakness
  • 384404 2023-002
    Material Weakness
  • 960843 2023-001
    Material Weakness
  • 960844 2023-002
    Material Weakness
  • 960845 2023-001
    Material Weakness
  • 960846 2023-002
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
66.458 Capitalization Grants for Clean Water State Revolving Funds $2.51M
66.468 Capitalization Grants for Drinking Water State Revolving Funds $2.51M
14.228 Community Development Block Grants/state's Program and Non-Entitlement Grants in Hawaii $417,846
21.027 Coronavirus State and Local Fiscal Recovery Funds $408,308
10.760 Water and Waste Disposal Systems for Rural Communities $360,543
16.835 Body Worn Camera Policy and Implementation $5,747
90.404 2018 Hava Election Security Grants $1,268