Finding Text
Finding No. 2023-002 - Procurement, Suspension and Debarment - Material Weakness
Name of Federal Agency: U.S. Department of Treasury
Federal Program Name: COVID-19: Coronavirus State and Local Fiscal Recovery Funds
Assistance Listing Number: 21.027
Federal Award Identification Number and Year: Not available
Name of Pass-through Entity (if applicable): City of Seattle, City of Scranton
Criteria
In accordance with §200.214 and §180.300, nonfederal entities cannot enter into awards, subawards, or contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities.
Condition
During our testing, we noted that the Organization did not provide adequate supporting documentation for ensuring proper suspension and debarment checks were performed.
Cause
The Organization did not have adequate policies, procedures, and controls in place to ensure compliance with the suspension and debarment requirements.
Effect or Potential Effect
Failure to timely verify that a recipient is not suspended or debarred could result in the Organization funding a person or entity that is barred from performing work for the U.S. government.
Questioned Costs
N/A
Context
For 5 suspension and debarment samples out of a total of 25 tested, management did not provide adequate supporting documentation for ensuring proper suspension and debarment checks were performed. None of the 5 samples were suspended or debarred.
Identification as a Repeat Finding
This finding is not a repeat finding.
Recommendation
We recommend that the Organization establish written suspension and debarment policies and procedures to ensure that the Organization is in compliance with the Uniform Guidance and that all staff are trained on this policy to ensure compliance and related internal controls over compliance are operating effectively.
Views of Responsible Officials
We will incorporate procedures in our grant compliance and administration policies and procedures that include appropriate searches for suspension and debarment prior to executing any financial transactions with covered persons.