Finding 42853 (2022-002)

2022-002 Suspension and Debarment Federal Agency Department of the Treasury Federal Program Name COVID 19 ? American Rescue Plan Act Assistance Listing Number 21.027 Federal Award Identification Number SLFRP5459 Grant Year 2021 Pass-Through Agency Connecticut Office of Policy and Management Pass-Through Number 12060-OPM20600-29669 Award Period March 3, 2021 ? December 31, 2026 Type of Finding Significant Deficiency in Internal Control over Compliance Criteria 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 The Town does not perform a review of Suspension and Debarment. Questioned Costs None Context Out of a population of seven, CliftonLarsonAllen LLP (CLA) tested five sealed bids to determine the Town included documentation noting a review of Suspension and Debarment. The sample was statistically valid. The Purchasing Agent indicated they do not perform a review, therefore, there is no documentation present. However, CLA noted none of the vendors for which ARPA expenditures were incurred were debarred per review of CT Suspension and Debarment list and SAM.gov Exclusion list. Effect The Town is at risk of entering into a transaction with a suspended or debarred entity if a proper review does not occur prior to the award of contracts with federal funds. Cause Proper controls over suspension and debarment are not in place. Recommendation CLA recommends that the Town perform a review to verify that contractors are not suspended or debarred prior to awarding them a contract. Further, it is recommended that the Town formally document that the review had been performed. A formal policy should be put into place so that this occurs on each applicable procurement. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding. The Town will include within the conditions of a sealed bid that a review over Suspension and Debarment will occur. Further, the Purchasing Agent will have a member of his team review this prior to signing any awards and the signature on the award will serve as a level of review.