Finding 479161 (2023-002)

Significant Deficiency
Requirement
I
Questioned Costs
-
Year
2023
Accepted
2024-07-23
Audit: 315668
Organization: Erath County, Texas (TX)
Auditor: Eide Bailly LLP

AI Summary

  • Core Issue: The County failed to keep records showing they checked if vendors were debarred before awarding SLFRF funds.
  • Impacted Requirements: This violates 2 CFR 200.303(a) and 31 CFR 19.300, which require proof of compliance with debarment checks.
  • Recommended Follow-Up: Implement a policy to document vendor debarment reviews at least twice a year to ensure compliance.

Finding Text

Finding 2023‐002: U.S. Department of the Treasury Federal Financial Assistance Listing 21.027 COVID‐19 Coronavirus State and Local Fiscal Recovery Funds Compliance Requirement: Procurement Suspension and Debarment Type of Finding: Significant Deficiency in Internal Controls over Compliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. Per 31 CFR 19.300, 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 § 19.300. Condition: The County did not maintain evidence of review of state and federal debarred vendor listing for three vendors receiving SLFRF funds. Cause: The County indicated review was performed, but no internal policy required the documentation of evidence of the review of SAM.gov and Texas Comptroller debarred vendor listings. Effect: No evidence that any SLFRF funds were provided to debarred vendors. Questioned Costs: None Context / Sampling: We tested 3 of 3 transactions subject to suspension and debarment in the SLFRF program. Repeat Finding from Prior Year: No Recommendation: To avoid the potential of missing review of the debarred vendor listings, the County should require documentation of review of the debarred vendor listings at least semi‐annually. Views of Responsible Officials: Management agrees with the noted finding. Refer to Corrective Action Plan.

Corrective Action Plan

Finding 2023‐002 Federal Agency Name: U.S. Department of the Treasury Program Name: COVID‐19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) Assistance Listing Number: 21.027 Finding Summary: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. Per 31 CFR 19.300, prior to enter in 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 § 19.300. The County did not review two counselors to determine that they were not suspended, debarred, or otherwise excluded prior to entering into a transaction with them. Responsible Individuals: Kent Reeves, County Auditor Corrective Action Plan: The County will start reviewing all vendors paid with federal funds against the sam.gov suspension and debarment review tool, and will document the periodic review of suspended and debarred vendors. Anticipated Completion Date: Fiscal year 2024

Categories

Procurement, Suspension & Debarment Subrecipient Monitoring

Other Findings in this Audit

  • 479160 2023-001
    Significant Deficiency
  • 1055602 2023-001
    Significant Deficiency
  • 1055603 2023-002
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
21.027 Coronavirus State and Local Fiscal Recovery Funds $1.63M