Finding 392118 (2022-002)

(MATERIAL WEAKNESS) – SUSPENDED AND DEBARRED PARTIES – ALN 21.027 – COVID-19 – CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS Condition The County did not have an effective process in place to ensure subrecipients of pass-through federal awards were not suspended or debarred from participating in federally-supported programs. Criteria The Federal Compliance Supplement and 2 CFR Section 180.300 requires grant recipients and subrecipients to verify contractors and subrecipients are not suspended or debarred from performing covered transactions. Such verification may include 1) checking the System for Award Management (SAM) Exclusions; 2) collecting a certification from the entity or 3) adding a clause or condition to the covered transaction with that entity. Cause Management was not aware of how to search for suspended or debarred parties on the SAM.gov website and did not have procedures to include explicit language in its subrecipient contracts/agreements. Recommendation We recommend the County adopt controls to ensure contractors and subrecipients are not suspended or debarred. Questioned Costs None noted Views of Responsible Officials The county added information to the Payment Request Form to make sub recipients aware that their organization along with any respective Contractors need an active UEI and must be registered in SAM. Effect There is a risk the County could enter into covered transactions with suspended or debarred parties.