Finding Text
Assistance Listing, Federal Agency, and Program Name - 21.027, U.S. Department of the Treasury, COVID-19 Coronavirus State and Local Fiscal Recovery Funds
Federal Award Identification Number and Year - 2023; 20-HA4-XC-03002, SLFRP0126
Pass-through Entity - Colorado Department of Local Affairs
Finding Type - Material weakness and material noncompliance with laws and regulations
Repeat Finding - No
Criteria - Per 2 CFR 180.300, before entering into a covered transaction with another person, grant recipients must verify that the person with whom they intend to do business is not excluded or disqualified. This is done by (a) checking SAM exclusions, (b) collecting a certification from that person, or (c) adding a clause or condition to the covered transaction with that person.
Condition - The City did not retain evidence that they performed the suspension and debarment check prior to entering into the contract.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - N/A
Context - One contract was selected for testing and it was noted that the City did not retain evidence that they performed the suspension and debarment check prior to entering into the contract. The City performed the check after the fact and noted that none of the contractors were suspended or debarred, therefore creating no questionned costs.
Cause and Effect - Controls in place did not ensure the City verified contractors paid were not excluded or disqualified prior to entering into transactions with the contractors.
Recommendation - We recommend the City establish a procedure to check for whether a contractor is suspended or debarred before entering into a contract and retain evidence of the search.
Views of Responsible Officials and Planned Corrective Actions - Procedures will be enhanced to ensure prior to entering into an agreement with an outside entity using federal funds, the City will perform the suspension and debarment check. Documentation of this review will be retained with the grant documents. In addition, the City will research grant management software options to further enhance grant monitoring.