Finding 392487 (2023-007)

CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS, ASSISTANCE LISTING No. 21.027, PROCUREMENT AND SUSPENSION AND DEBARMENT Criteria: Per section 13 of Treasury’s Final Rule FAQs and 2 CFR 200.214, recipients are prohibited from using SLFRF funds to enter into subawards and contracts with parties at a lower tier, (a contractor, subcontractor, individual or supplier) that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs. Condition: The county did not verify eligibility for participation in the federal program for its third-party suppliers and contractors. Questioned Costs: None Cause: The county does not have procurement policies and procedures in place that allow it to comply with procurement standards outlined in the Uniform Guidance. Effect: Non-compliance with program terms and conditions Recommendation: The county should develop a process to verify that all required parties are not suspended or debarred or otherwise excluded from participation in the federal program. 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 https://www.sam.gov/portal/public/SAM, (2) collecting a certification from the entity, or (3) adding a clause or condition to the transaction with that entity (2 CFR section 180.300). Views of responsible officials and planned corrective actions: The government agrees with this finding and will adhere to the attached corrective action plan.