Finding Text
2023-003 Federal Agency: U.S. Department of the Treasury
Program/Cluster: COVID-19 Coronavirus State and Local Fiscal Recovery Funds
Federal Financial Assistance Listing Number: 21.027
Pass-through: N/A
Award No. and Year: N/A, 2022
Compliance Requirement: Procurement, suspension and debarment
Type of Finding: Significant Deficiency in Internal Control Over Compliance, Instance of Noncompliance
Criteria:
Per 2 CFR part 200, subpart D, section 200.303, the nonfederal entity must establish and
maintain effective internal control over the federal award that provides reasonable assurance
that the nonfederal entity is managing the federal award in compliance with federal statues,
regulations, and the terms and conditions of the federal award.
Prior to entering into subawards and contracts with award funds, recipients must verify that
such contractors and subrecipients are not suspended, debarred, or otherwise excluded
pursuant to 31 CFR section 19.300.
Condition:
In 1 instance out of 4 procurements sampled, we could not evidence that management had
reviewed the debarment status of a vendor at the time of entering into the contract/agreement,
and the agreement did not include a clause regarding debarment status, nor did management
obtain a certification of the vendor’s status from the vendor.
Cause:
The contract/agreement template used by the City did not include the debarment status clause,
and management described that a debarment status check was performed on sam.gov at the
time of entering into the agreement; however, the project manager overseeing the agreement
who retained that documentation is no longer working for the City, and management could not
locate the record of the debarment status check being performed.
Effect:
Entering into contracts with vendors could result in disbursement of Federal funds to suspended
or debarred parties.
Questioned Costs:
None noted.
Context/Sampling:
A nonstatistical sample of 4 out of 8 contracts were selected. We found that none of the
selected vendors were suspended or debarred.
Repeat Finding from Prior Year:
No.
Recommendation:
We recommend that the City review its procedures for retaining documentation evidencing the
debarment status verifications performed for contracts and agreements through sam.gov.
Views of Responsible Officials and Planned Corrective Action:
Management agrees with the finding. See separate corrective action plan.