FAC Explorer

Finding 48451 (2022-001)

Significant Deficiency
Requirement
I
Questioned Costs
-
Year
2022
Accepted
2023-01-04
Audit: 51042
Organization: Park County (WY)
Auditor: Carver Florek & James Cpa's

AI Summary

  • Core Issue: The County lacks written standards to verify that vendors are not suspended or debarred before contracts are signed.
  • Impacted Requirements: This violates 2 CFR 200.318(h) and 2 CFR 180, and the conflicts of interest policy is insufficient.
  • Recommended Follow-Up: Implement clear written policies on vendor verification and conflicts of interest, and ensure personnel receive grant administration training.

Finding Text

Information on the Federal Program: Assistance Listing Number: 21.027 Department Agency: Department of the Treasury State Department: n/a - Direct Compliance Area: Procurement & Suspension & Debarment (I) Criteria: The County should have written standards of conduct in place to verify any entity(vendor) with which the County spends federal expenditures or conducts business transactions be not debarred, suspended, or otherwise excluded per 2 CFR 200.318(h) and 2 CFR 180. The written standard should address conduct covering conflicts of interest governing the performance of its employees engaged in the selection, award, and administration of contracts (Uniform Guidance Section 200.318(c) and 45 CFR sections 52.203-13 and 52.203-16). Condition: The County did not have written controls in place to ensure that vendors were not suspended or debarred or included on the list of vendors prior to entering into a contract with the County. Additionally, we found the County?s written conflicts of interest policy to be vague. Cause: County personnel have not obtained sufficient training related to grant administration. Effect or Potential Effect: The County could enter into a contract with a suspended or debarred party or have a conflict of interest that is undetected. Questioned Costs: None. Repeat Finding: No. Recommendation: The County should adopt written policies that satisfy the requirements of Uniform Guidance associated with suspension, debarment, and conflicts of interest. Furthermore, we recommend that County personnel seek out training related to grant administration. Views of Responsible Official: See the following page for the County?s response to this finding.

Corrective Action Plan

To Whom It May Concern: This is in answer to finding 2022-001 for the Carver, Florek & James CPA's Auditors for the findings in Park County's 2022 Audit. Page 53 - Responses for Finding 2022-001 Written Debarred, Suspended Vendors & Federal Standards of Conflict of Interest A second user (accounts payable) was set up in November 2022 to search for entities that we pay with federal dollars to make sure they are in good standing with Sam.Gov before paying any dollars to those entities. The County will investigate seeking out training with Government Finance Officers Association (GFOA) to see what is available that would help with grant administration by February 2023. The County will add some wording to the Procurement Policy to make sure all departments that use grants will know the procedures regarding debarred or suspended vendors with a completion date of February 2023. The County Clerk, Colleen Renner, will be responsible for ensuring these actions are initiated and completed. Colleen Renner Park County Clerk

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 624893 2022-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
21.027 Coronavirus State and Local Fiscal Recovery Funds $559,574
93.243 Substance Abuse and Mental Health Services_projects of Regional and National Significance $188,590
93.558 Temporary Assistance for Needy Families $63,826
93.354 Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response $54,716
97.042 Emergency Management Performance Grants $48,500
97.067 Homeland Security Grant Program $47,132
16.575 Crime Victim Assistance $28,172
21.019 Coronavirus Relief Fund $18,020
16.588 Violence Against Women Formula Grants $10,911
93.069 Public Health Emergency Preparedness $9,540
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $8,511
93.268 Immunization Cooperative Agreements $7,984