Finding 38917 (2022-001)

-
Requirement
I
Questioned Costs
-
Year
2022
Accepted
2023-09-18
Audit: 44334
Organization: City of Liberty, Missouri (MO)
Auditor: Forvis

AI Summary

  • Core Issue: The City did not perform required suspension and debarment checks on all vendors before purchasing goods with federal funds.
  • Impacted Requirements: This oversight violates 2 CFR Section 180.220, which mandates checks to prevent transactions with suspended or debarred entities.
  • Recommended Follow-Up: Update policies to ensure suspension and debarment checks are conducted prior to vendor purchases, and confirm management's corrective action plan is implemented.

Finding Text

U.S. Department of Treasury, Coronavirus State and Local Fiscal Recovery Funds - 21.027 Award Period: January 1, 2022 - December 31, 2022 Criteria or Specific Requirement - Procurement In accordance with 2 CFR Section 180.220, 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, 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. Condition - Suspension and debarment checks were not completed for all vendors that received federal funds. Questioned Costs - None noted. Context - One of five vendors subject to procurement requirements in 2022 was selected for testing. The City purchased approximately $306,000 in goods from this vendor in 2022. During our testing, it was noted that the City did not check the vendor's suspension and debarment status prior to purchase. The City completed the suspension and debarment check subsequent to purchase and verified that the vendor was not suspended or disbarred. The sample was not intended to be, and was not, a statistically valid sample. Effect - Federal funds could be paid to entities that are suspended or debarred. Cause - The City's controls to ensure suspension and debarment checks were performed on vendors receiving federal funds did not operate effectively. Identification as a Repeat Finding, if applicable - Not a repeat finding. Recommendation - Policies and procedures should be modified to ensure that suspension and debarment checks are performed on vendors prior to making purchases with federal funds. View of Responsible Official and Planned Corrective Actions ? Management agrees with the stated finding and has implemented a corrective action plan.

Corrective Action Plan

Personnel Responsible for Corrective Action ? Jenny Trout, Accounting Manager Anticipated Completion Date ? 08/01/2023 Corrective Action Plan ? Debarment should be checked prior to purchasing or contracting with any entity or agency to ensure the entity or agency has not been Debarred or Suspended by the federal government at the System for Award Management (SAM.gov) website (http://www.sam.gov/). The SAM website must be checked to verify the entity or agency has not been Debarred or Suspended prior to entering into an award with an entity or agency with federal dollars, and annually checked for the life of the Federally Funded award and documented with a screenshot of the documentation. If at any time the SAM.gov website indicates the subrecipient has active exclusions, no invoices will be paid until the entity or agency is removed from the exclusion listing.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
21.027 Covid-19 Coronavirus State and Local Fiscal Recovery Funds $2.14M
94.002 Americorps Seniors Retired and Senior Volunteer Program (rsvp) $67,444
93.044 Special Programs for the Aging_title Iii, Part B_grants for Supportive Services and Senior Centers $36,950
93.045 Special Programs for the Aging_title Iii, Part C_nutrition Services $25,188
20.600 State and Community Highway Safety $5,818
93.043 Special Programs for the Aging_title Iii, Part D_disease Prevention and Health Promotion Services $3,880
20.607 Alcohol Open Container Requirements $2,767
93.053 Nutrition Services Incentive Program $2,267
93.667 Social Services Block Grant $707