Finding 479434 (2023-002)

Federal Agency: U.S. Department of Treasury Federal Program Names: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Numbers: 21.027 Pass-Through Agency: Wisconsin Department of Health Services Pass-Through Numbers: 155811 and 2021-VO-A/VO-01-17452 Federal Award Identification Number and Year: SLFRF1158; 2020 Award Periods: March 1, 2020 – December 31, 2024 Type of Finding Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement 2 CFR 200 states that nonfederal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a nonprocurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220). All nonprocurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition The City does not have a policy and procedure relating to suspension and debarment, they do not meet Uniform Guidance requirements. Questioned Costs None. Context While performing compliance procedures, it was noted that suspension and debarment procedures and policies were not in place. Cause The City does not have a policy and procedure relating to suspension and debarment. The City does not follow Uniform Guidance. Effect The County is not in compliance with suspension and debarment requirements. Vendors may be paid with federal funds that are suspended and debarred entities which would not be in compliance with the Uniform Guidance.Repeat Finding No Recommendation We recommend the County review and update procurement policies for the entire County to include suspension and debarment to ensure it meets the minimum requirements of 2 CFR 200 for all federal grants. View of Responsible Officials There is no disagreement with the finding.