Finding Text
Finding 2023-002 - Significant Deficiency, Compliance
Federal Assistance Listing Number. 21.027
U.S. Department Of Treasury
State And Local Fiscal Recovery Funds – Suspension And Debarment
Criteria: According to Part 3 of the 2024 Compliance Supplement “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. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300).
Condition: In our nonstatistical sample of 5 procurement transactions for the year ended December 31, 2023, we identified 4 procurement transactions where no suspension and debarment certification was documented prior to the execution of the contract or clause was added to the contract and for which the suspension and debarment check on SAM.gov was not included in the contract file.
Context: EnterpriseKC completed the suspension and debarment checks on SAM.gov but could not provide evidence that those checks were completed in 2023 at or before the date in which the contract was executed. Instead, the suspension and debarment checks were added to the contract files after our audit procedures were conducted.
Effect: A failure to result in conducting a suspension and debarment check could result in procuring goods or services from an unallowed vendor which could result in unallowable costs. EnterpriseKC was able to show that all vendors used in 2023 were not included on the Exclusions list and were not suspended and debarred.
Questioned Costs: There were no questioned costs identified.
Cause: EnterpriseKC was not aware of the requirements to maintain documentation of the suspension and debarment checks in the contract files.
Identification Of Repeat Finding: This is not a repeat finding.
Recommendation: We recommend that EnterpriseKC conduct the suspension and debarment checks and retain documentation of those checks in the contract files and establish controls to ensure that review of the contract files include ensuring the checks are complete.
Views Of Responsible Officials (Unaudited): EnterpriseKC has conducted the suspension and debarment checks and has included those checks in the contract files for all covered transactions and has also updated its procedures to ensure those checks are conducted and added to the contract file at or before the contract effective date.
Completion Date: August 2024
Contact Person: Jay Konomos, Pillar Leader