Finding 504796 (2024-001)

Finding 2024-001: Suspension & Debarment Federal Program: Coronavirus State and Local Fiscal Recovery Funds, ALN 21.027, Award No. 43007444 Federal Agency: U.S. Department of the Treasury Federal Award Year: January 18, 2023 - December 31, 2026 SIGNIFICANT DEFICIENCY Criteria: Government-wide requirements related to suspension and debarment and doing business with suspended or debarred subcontractors under cost reimbursement contracts under the FAR are contained in 48 CFR section 9.405-2(b) and the clause at 48 CFR section 52.209-6. In accordance with those regulations, non-federal entities are prohibited from contracting with or making subawards to entities that are suspended or debarred. Condition: During our test work over the Coronavirus State and Local Fiscal Recovery Funds, we selected a sample of 40 vendor transactions with expenditures totaling $1,017,917. Within our sample, we noted 4 transactions with one vendor totaling $627,155, for which the Organization did not perform the required verification that the vendor was not suspended, debarred, or otherwise excluded from participating in a covered transaction. It was determined that this vendor was not suspended or debarred; however, the Organization did not follow its policies and procedures to ensure that this verification occurred before entering into the related contract. Effect: Federal funds may be expended under covered transactions with vendors that are disallowed from participating in the federal award program. Cause: Management did not follow the Organization’s policies and procedures, which require documentation of the verification that a vendor is not suspended or debarred before entering into a covered transaction. Questioned Costs: $0 Context: Our sample of 40 transactions totaling $1,017,917 represented approximately 52 percent of the total expenditures for the federal award program for the year ended June 30, 2024, and included 19 different vendors. We noted one vendor for which the required suspension and debarment check was not completed. Of our sample, 4 transactions totaling $627,155 were related to this vendor. In total, 20 transactions amounting to $1,290,965 were incurred with this vendor and charged to the federal program for the year ended June 30, 2024. The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend that management strengthen the Organization’s review procedures to help to ensure that all required vendor reviews are being conducted prior to entering into covered transactions. Management Response: Management agrees with this finding. See Corrective Action Plan.