Finding 385032 (2023-001)

Significant Deficiency
Requirement
I
Questioned Costs
-
Year
2023
Accepted
2024-03-26
Audit: 298129
Organization: Town of Chelmsford (MA)

AI Summary

  • Core Issue: The Town failed to document vendor verification against suspension or debarment from federal assistance programs.
  • Impacted Requirements: This violates compliance requirements under 2 CFR Part 200.214 regarding vendor eligibility.
  • Recommended Follow-Up: Implement annual documentation procedures to verify that all vendors are not suspended or debarred.

Finding Text

Federal Agency: U.S. Department of Treasury Federal Program Name: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Pass-Through Agency: Massachusetts Department of Revenue Pass-Through Number: ARPACNTYSH056 Award Period: July 1, 2022 – June 30, 2023 Type of Finding: Significant Deficiency in Internal Control Over Compliance Compliance Requirement: Suspension and Debarment Criteria or Specific Requirement: The Code of Federal Regulations (CFR) Title 2 Part 200.214 states that nonfederal entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations 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. Nonfederal entities must verify that contracts with certain parties are not debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition and Context: For all vendors in our audit sample, the Town did not document verification that the vendor was not suspended or debarred from participation in Federal assistance programs or activities. The vendors in our audit sample were not suspended or debarred. Questioned Costs: None. Cause: Procedures were not in place to document the verification that all vendors were not suspended or debarred from participation in Federal assistance programs or activities. Effect: While this did not occur in the instances identified in this finding, lack of verification of vendors’ debarment or suspension status could cause federal grant funds to be expended with vendors that are excluded from participation in Federal assistance programs or activities. Repeat Finding: No. Recommendation: We recommend to annually (at a minimum) document the verification that all vendors are not suspended or debarred from participation in Federal assistance programs or activities. Views of Responsible Officials: Management agrees with the finding.

Corrective Action Plan

The Town of Chelmsford, Massachusetts respectfully submits the following corrective action plan for the year ended June 30, 2023. Audit period: July 1, 2022 – June 30, 2023 The finding from the schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. FINDING—FEDERAL AWARD PROGRAMS AUDITS DEPARTMENT OF TREASURY 2023-001 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds – Assistance Listing Number 21.027 Recommendation: We recommend to annually (at a minimum) document the verification that all vendors are not suspended or debarred from participation in Federal assistance programs or activities. Explanation of disagreement with audit finding: There is no disagreement with the audit finding and agrees that the vendors were not suspended or disbarred. Action taken in response to finding: The Town has implemented procedures to document the verifications with either contract certifications and/or screenshots of SAM.gov searches. Name(s) of the contact person(s) responsible for corrective action: Town Management and Finance. Planned completion date for corrective action plan: Completed.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 961474 2023-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
21.027 Coronavirus State and Local Fiscal Recovery Funds $2.69M
84.425 Education Stabilization Fund $608,586
84.010 Title I Grants to Local Educational Agencies $258,737
10.553 School Breakfast Program $181,413
10.555 National School Lunch Program $141,704
84.027 Special Education_grants to States $104,786
84.367 Improving Teacher Quality State Grants $86,616
84.365 English Language Acquisition State Grants $36,581
97.044 Assistance to Firefighters Grant $30,064
84.424 Student Support and Academic Enrichment Program $17,744
84.173 Special Education_preschool Grants $9,687
16.607 Bulletproof Vest Partnership Program $9,671
97.042 Emergency Management Performance Grants $9,500