Finding Text
Information on the
Federal Program: Federal Agency: United States Department of Transportation
Program Name: Federal Transit Cluster
AL: 20.507
Federal Award Year: 2023
Federal Agency: United States Department of Transportation
Program Name: Formula Grants for Rural Areas
AL: 20.509
Federal Award Year: 2023
Criteria: Required by 2 CFR, Part 200 for federally funded programs, when an institution enters into a covered transaction with an entity or individual, an institution must verify that the vendor or employee is not suspended or debarred or otherwise excluded from participating in federal programs. Generally, a covered transaction is a transaction expected to equal or exceed $25,000 and be funded with federal dollars. This verification may be accomplished by checking the System for Award Management (SAM), formerly the Excluded Parties List System, maintained by the General Services Administration, collecting a certification from the vendor, or by adding a clause or condition to the covered transaction.
Condition Found: During our audit, we noted the District did not consistently review the SAM for vendors meeting the covered transaction threshold.
Context: Based on our testing, we noted that none of the vendors selected in our testing that were charged to the grant were included in the SAM listing. Although we did note the District has a process to review SAM for vendors during the procurement process and during prior to payment to vendors, this review does not consistently occur.
Questioned Costs: None noted
Cause and Effect: The District is aware of the requirement to verify vendors against the SAM. Since this process was not performed on all vendors, there was a risk vendors who may be included on the SAM were included in the expenditures for the federal program.
Identification as a
Repeat Finding,
if applicable: N/A
Recommendation: We recommend the District implement a process to verify all vendors prior to payment against the SAM. We also recommend the District provide additional training to all individuals involved in the accounts payable and procurement on the importance of the SAM reviews.
Views of a
Responsible
Official and
Corrective
Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan on page 40.
Responsible party: Laurie Bowie, (207) 774-7874