Finding 393486 (2023-001)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2023
Accepted
2024-04-16
Audit: 303681
Organization: Town of Foster, Rhode Island (RI)

AI Summary

  • Core Issue: The Town of Foster lacks procedures to verify if entities are suspended or debarred before entering into covered transactions with federal funds.
  • Impacted Requirements: This finding violates federal regulations requiring verification for contracts over $25,000, particularly for the Coronavirus State and Local Fiscal Recovery Funds.
  • Recommended Follow-Up: Implement verification procedures immediately to ensure compliance and prevent future violations, as this is a repeat finding from the previous audit.

Finding Text

Finding: 2023-001-Material Weakness Agency: U.S. Department of the Treasury Program: Coronavirus State and Local Fiscal Recovery Funds Federal Assistance Listing Number: 21.027 SUSPENSION AND DEBARMENT Criteria - 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. “Covered transactions” include those procurement contracts for goods and services awarded under non-procurement transaction (e.g. grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR Section 180.220. This requirement applies to contracts entered into to procure goods and services with Coronavirus State and Local Fiscal Recovery Funds. Condition - The Town of Foster does not have a specific procedure in place for verifying that an entity with which it plans to enter into a covered transaction is not suspended, debarred or otherwise excluded. Cause - The Town has not established suspension and debarment policies and procedures for federal awards. Effect – Contracts for goods and service that were “covered transactions” were entered into prior to verifying that an entity was not suspended, debarred or otherwise excluded. Questioned Costs – None Identification of a Repeat Finding- This is a repeat finding from the previous audit 2022-001. Recommendation- We recommend that the Town implement verfication procedures to ensure that an entity with which it plans to enter into a covered transaction is not suspended, debarred or otherwise excluded. Auditee’s Views- Management implemented a Corrective Action Plan for all future contracts awarded. These procedures include adding the required contract language to all contracts and obtaining the professional’s certification that they are not suspended, debarred, or otherwise excluded from participating in the transaction at the time of contract award. In addition, prior to award, the entity confirms through the System for Award Management (SAM.gov) website that the contractor is not suspended, debarred, or otherwise excluded from participating in the transaction. This process was not implemented until late in the 2023 fiscal year.

Corrective Action Plan

Town of Foster, Rhode Island Corrective Action Plan For the Fiscal Year Ended June 30, 2023 Section III-Federal Award Findings and Questioned Costs Finding: 2023-001 Corrective Action Plan - Management implemented a Corrective Action Plan for all future contracts awarded. These procedures include adding the required contract language to all contracts and obtaining the professional’s certification that they are not suspended, debarred, or otherwise excluded from participating in the transaction at the time of contract award. In addition, prior to award, the entity confirms through the System for Award Management (SAM.gov) website that the contractor is not suspended, debarred, or otherwise excluded from participating in the transaction. This process was not implemented until late in the 2023 fiscal year. Anticipated Completion Date – Completed Contact Person – Kelli Russ, Finance Director

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 969928 2023-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.425 Education Stabilization Fund $233,264
21.027 Coronavirus State and Local Fiscal Recovery Funds $196,343
84.027 Special Education_grants to States $92,759
84.010 Title I Grants to Local Educational Agencies $53,724
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $52,374
90.404 2018 Hava Election Security Grants $38,020
10.553 School Breakfast Program $23,289
84.173 Special Education_preschool Grants $15,166
84.358 Rural Education $15,122
84.367 Improving Teacher Quality State Grants $14,351
84.424 Student Support and Academic Enrichment Program $10,000
10.555 National School Lunch Program $9,460
20.600 State and Community Highway Safety $4,780
93.069 Public Health Emergency Preparedness $4,333