Finding 395807 (2022-001)

Suspension and Debarment Prior Year Finding Number: N/A Repeat Finding Since: N/A Type of Finding: Internal Control Over Compliance and Compliance Severity of Deficiency: Significant Deficiency and Other Matter Federal Agency: U.S. Department of the Treasury Program: 21.027 COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Award Number and Year: Federal Direct; 2022 Pass-Through Agency: N/A - Direct Criteria: Federal requirements prohibit non-federal entities from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Title 2 U.S. Code of Federal Regulations § 180.300 describes a required verification process. Prior to entering into the transaction, one of the following must be performed: (1) checking SAM.gov exclusions, (2) collecting a certification, or (3) adding a clause or condition to the covered transaction. The suspension and debarment requirements apply to covered transaction amounts over $25,000. Condition: For three covered transactions selected for testing, the verification for suspended or debarred vendors was not performed before entering into the covered transactions. Questioned Costs: None. Context: The County entered into a total of 29 covered transactions over the $25,000 threshold for this grant. In addition, after this was brought to the County’s attention, the County verified that these vendors were not suspended or debarred. The sample size was based on guidance from chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits. Effect: Failure to verify vendors are not suspended or debarred may result in the County entering into a transaction with a vendor that is not authorized to provide goods and services. Cause: The County has procedures in place to perform verification and retain documentation; however, due to staffing shortages and timing, the procedures were not performed. Recommendation: We recommend the County maintain documentation to demonstrate that vendors are not debarred, suspended, or otherwise excluded; this documentation should be completed prior to entering into a covered transaction. View of Responsible Official: Concur