Finding Text
SA2023-001: Lack of Verification for Suspension or Debarment
Assistance Listing Numbers: 21.027
Assistance Listing Title: Coronavirus State and Local Fiscal Recovery Funds
Name of Federal Agency: U.S. Department of Treasury
Criteria:
Per 2 CFR section 180.300, when a non-federal entity enters into a covered transaction with an entity at a
lower tier, the non-federal entity must verify that the entity is not suspended or debarred or otherwise
excluded from participating in the transaction. This verification may be accomplished by (1) checking the
System for Award Management (SAM) Exclusions maintained by the General Services Administration
(GSA) and available at SAM.gov (2) collecting a certification from the entity, or (3) adding a clause or
condition to the covered transaction with that entity.
Condition:
The City failed to provide evidence demonstrating the verification of HR&A Advisors, Inc's eligibility
before entering into a procurement contract.
Cause:
The absence of proof indicating the verification of HR&A Advisors, Inc's eligibility for participation in the
transaction can be attributed to inadequate internal controls and oversight mechanisms within the City's
procurement processes. It appears that the City's procedures did not sufficiently address the requirement
for verifying the suspension or debarment status of potential contractors.
Context and Effect:
Without verification process in place, the City may inadvertently enter into contracts with ineligible parties.
Recommendation:
The City should strengthen internal controls and procedural guidelines related to procurement processes to
explicitly include the verification of suspension or debarment status for potential contractors, aligning with
the requirements of 2 CFR section 180.300.
Management Response: