Finding Text
Federal Program: Coronavirus State and Local Fiscal Recovery Funds (21.027). Criteria: According to 2 CFR Section 180.300, when non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity is not suspended, debarred, or otherwise excluded. Condition: The County had transactions in excess of $25,000 with five vendors in which they did not verify that the entitites were not suspended, debarred, or otherwise excluded. Cause: The County overlooked this procedure on these frequently used vendors and/or cooperative agreements. Effect: The County was at risk of making material payments to a vendor who is not allowed to do business with the federal government. There was no noncompliance, but tehre was no internal control in place to prevent noncompliance. Questioned Costs: None. Context: Payments to the five vendors totaled $889,124. Total payments from the program totaled $2,276,521. As noted above, there was no noncompliance, but there was not internal controls in place to ensure noncompliance. Repeat Finding: No. Recommendation: We recommend the County check the excluded parties list system or collect certification from the entity for any vendor in which the County expects to spend more than $25,000 of federal grant funds for the year. Views of Responsible Officials and Planned Corrective Actions: We will ensure that controls are in place to check the status of potential vendors going forward. All agreements and bid terms utilizing federal grant funds will contain a certification statement for federal debarment and suspension. These controls will be reviewed by all elected officials and department heads.