Finding 479454 (2023-001)

Significant Deficiency Repeat Finding
Requirement
I
Questioned Costs
-
Year
2023
Accepted
2024-07-25

AI Summary

  • Core Issue: The Chamber failed to check if vendors were suspended or debarred, violating OMB guidance.
  • Impacted Requirements: Non-compliance with procurement policies could lead to contracts with ineligible vendors.
  • Recommended Follow-up: Implement verification procedures for vendor status and include suspension/debarment clauses in all relevant contracts.

Finding Text

Funding Agency: U.S. Department of the Treasury Federal ALN: 21.027 Criteria Per OMB guidance, non-federal entities are prohibited from contracting with parties that are suspended or debarred, or whose principals are suspended or debarred. Condition The Chamber has a procurement policy in place; however, the Chamber neglected to verify if vendors had been suspended or debarred, in accordance with stated regulations. Context Per our review of vendors over the applicable threshold, there was no documentation of having been reviewed for suspension or debarment. Cause Staff claimed that they had been conducting business transactions with these vendors prior to having a procurement policy in place and did not implement the procurement policy on already developed business relationships. Effect Purchases may have occurred that do not follow the policy, and contracts to vendors that had been suspended or debarred could have been awarded and not detected. Auditor's Recommendations Tacoma-Pierce County Chamber of Commerce should include a provision in all contracts transacted in conjunction with using funds originating from a federal award grant, with respect to suspension and debarment, communicate all requirements for procurement to staff and establish procedures to verify that vendors are not suspended or debarred.

Corrective Action Plan

Corrective Action Plan for Annual Audit 2023 Finding One: 2023-001 Procurement, Suspension and Debarment Auditor’s Recommendations: Tacoma-Pierce County Chamber of Commerce should include a provision in all contracts transacted in conjunction with using funds originating from a federal award grant, with respect to suspension and debarment, communicate all requirements for procurement to staff and establish procedures to verify that vendors are not suspended or debarred. Corrective Action: CEO, Andrea Reay, will develop a process for checking and documenting vendor suspension and debarment status as required in the established procurement policy. CEO will be responsible for verifying that all vendors being paid using Federal Funds, will have been checked for suspension and debarment prior to disbursing future Federal funding and document the search process. The Chamber employees who authorize the use of Federal funds will: Read and sign a document stating that they are aware of the Federal provisions requiring concerning Suspension and Debarment Confirm with the CEO, or appropriate delegee that the vendor has been checked prior to fund distribution using the SAM.gov registration. Timing of remediation completion: CEO, Andrea Reay, will complete by May 31, 2024.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 1055896 2023-001
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
21.027 Coronavirus State and Local Fiscal Recovery Funds $786,451
14.228 Community Development Block Grants/state's Program and Non-Entitlement Grants in Hawaii $171,186