Finding Text
Assistance Listing, Federal Agency, and Program Name - ALN 21.027, U.S. Department of the Treasury, Coronavirus State and Local Fiscal Recovery Funds
Federal Award Identification Number and Year - 21.027, fiscal year 2023
Pass-through Entity - N/A
Finding Type - Material weakness and material noncompliance with laws and regulations
Repeat Finding - No
Criteria - Per 2 CFR Section 180.300, recipients must have procedures in place for verifying that an entity with which they plan to enter into a covered transaction is not debarred, suspended, or otherwise excluded.
Condition - The Township did not verify and maintain support for verification that contractors are not suspended, debarred, or otherwise excluded pursuant to 2 CFR Section 180.300 prior to entering into contracts with award funds.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - N/A
Context - 2 out of 11 contracts procured during the year that were selected for testing did not include adequate documentation regarding review that the contractor was not debarred, suspended, or otherwise excluded prior to entering into the contract. The Township has since confirmed, as of the date of the audit, that that contractors were not on the suspended or debarred list, and, therefore, there are no questioned costs.
Cause and Effect Internal control procedures related to compliance with suspension and debarment requirements did not operate effectively. As a result, the Township did not perform procedures required under 2 CFR 180.300.
Recommendation - Internal control procedures should be implemented to ensure that all contracts include verification that an entity is not debarred, suspended, or otherwise excluded and that documentation of this review is maintained in the contract file.
Views of Responsible Officials and Corrective Action Plan - The Township will implement a process to ensure that prospective contractors are not suspended or debarred prior to entering into a contract and will maintain documentation supporting this conclusion. When awarding a contract to future prospective contractors, the Township or a representative of the Township will check SAM.gov listings for the prospective vendor and/or include a self certification as part of the bidding process.