Finding Text
Finding 2023-003: Coronavirus State and Local Fiscal Recovery Funds – Suspension and Debarment Requirements
U.S. Department of the Treasury, Passed through the City of Pittsburgh and the Commonwealth of Pennsylvania, Department of Community and Economic Development- Assistance Listing Number 21.027
Condition: During 2023, the URA did not follow the internal control procedures to ensure all covered contracts and subawards were not conducted with entities that are suspended and debarred. The URA’s current process is supposed to ensure that all contracts, agreements, and grants include a clause or condition that the entity is not suspended or debarred. We reviewed a sample of covered transactions and noted that 17 out of 20 transactions did not have the suspension and debarment clause within the agreement. In conjunction with the audit, we reviewed the System for Award Management (SAM) Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred.
Criteria: Under compliance requirements set forth for the program, the URA is 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 non-procurement 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. 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.
Cause: The URA did not follow the internal control process of including a suspension and debarment clause within its contracts, agreements, and grants to ensure the URA was not entering into a covered transaction with a suspended or debarred entity.
Effect: As the URA did not include a suspension and debarment clause within the contracts, agreements, and grants for its covered transactions, the URA risks not being in compliance with suspension and debarment requirements for the Coronavirus State and Local Fiscal Recovery Funds program.
Questioned Costs: Unknown
Identification as a Repeat Finding: This is not a repeat finding.
Recommendation: The URA should follow the internal control procedure of adding a suspension and debarment clause within its contracts, agreements, and grants for covered transactions.
Views of responsible officials and Planned Corrective Action: Management agrees with this finding; see separate Corrective Action Plan.